FBAR for Americans in Europe: Who Files and How (2026 Guide)

The FBAR is a yearly report that US persons file to disclose their foreign financial accounts. You must file it if the combined maximum values of all your foreign accounts exceeded $10,000 at any time during the calendar year. Many Americans living in Europe cross that line once they add up a local bank account, a fintech account and any pension or savings abroad.

The FBAR is FinCEN Form 114. You file it online with FinCEN, separately from your tax return. As of October 2026, the FBAR covering your 2026 accounts is due April 15, 2027, with an automatic extension to October 15, 2027. This guide covers who has to file, what counts toward the $10,000, how to convert euros and how to e-file step by step.

Key facts at a glance

Question	Short answer
What is the form?	FinCEN Form 114, Report of Foreign Bank and Financial Accounts
Who files?	US persons with foreign accounts worth more than $10,000 combined at any time in the year
How is $10,000 measured?	The sum of each account's maximum value during the year, not the December 31 balance
Where do you file?	FinCEN's BSA E-Filing System, not the IRS and not with Form 1040
Cost to file yourself	Free
2026 accounts deadline	April 15, 2027, automatic extension to October 15, 2027
Exchange rate	Treasury Reporting Rate of Exchange for December 31 of the reporting year
Records	Keep for five years from the FBAR due date
Max non-willful penalty (2026)	$16,536 per annual report

What is FBAR and who has to file it?

FBAR stands for Report of Foreign Bank and Financial Accounts. A US person with a financial interest in, or signature or other authority over, foreign financial accounts must file an FBAR if the aggregate value of those accounts exceeded $10,000 at any time during the calendar year, according to FinCEN.

"US person" is broader than many people expect. The IRS says it includes citizens, residents, corporations, partnerships, LLCs, trusts and estates. The IRS also says an account at a financial institution located outside the US is generally a foreign financial account.

Two points trip people up early. First, "signature or other authority" can mean reporting an account that is not yours, such as an employer's company account you can sign on, or a parent's account in Germany you manage under a power of attorney. Whether a power of attorney counts depends on whether the bank will act on your instructions directly, and some employees of regulated or publicly traded US companies are exempt, so check the FinCEN FBAR instructions or ask an adviser.

Second, the FBAR is an information report, not a tax. The test depends on account values, not on how much US tax you owe. If you owe nothing because of the Foreign Earned Income Exclusion, you still file the FBAR when your accounts cross the threshold.

FBAR rules depend on your exact facts, so confirm your own case with the official FinCEN and IRS pages or a qualified US tax adviser.

Do you need to file an FBAR if your accounts are under $10,000?

You do not need to file if the combined maximum values of all your foreign accounts stayed at $10,000 or less for the whole year. But "under $10,000" has to be true of the total, not of each account and not of your year-end balance.

How the aggregate rule works

The $10,000 test adds up the maximum value each foreign account reached during the year. It is not tested account by account, and it is not the December 31 balance. FileAbroad gives a simple example: $6,000 in one account plus $5,000 in another is $11,000, so the FBAR is required, even though neither account alone passed $10,000.

Here is what that means in practice:

One euro account with about $11,000 in it: yes, you file.
A brief spike: if you moved $80,000 into a Spanish account for three days to close on an apartment, your maximum value for that account is about $80,000. One day over the line is enough.
Your US savings: accounts at US institutions are not foreign accounts, so a $40,000 balance at a bank in Ohio does not count toward the $10,000.
Several small accounts: a local checking account, a savings pot and a fintech card can push you over together.

Worked example: a retiree in Valencia

Say you are a 64-year-old retiree from Michigan living in Valencia on Social Security. During 2026 you had these accounts:

Spanish bank checking account: highest balance €7,000 (in June, after a pension transfer)
Revolut account with a Lithuanian IBAN: highest balance €2,500
Your US credit union account: $30,000 (not foreign, so ignored)

To keep the math simple, assume the Treasury Reporting Rate for December 31, 2026 turns out to be 0.90 euros per US dollar. This rate is for illustration only, and you must look up the real published rate when you file. Treasury quotes the rate as units of foreign currency per one dollar, so you divide the euro amount by the rate:

Spanish account: €7,000 ÷ 0.90 = $7,777.78, rounded up to $7,778
Revolut: €2,500 ÷ 0.90 = $2,777.78, rounded up to $2,778
Aggregate maximum value: $10,556

That total is above $10,000, so you file an FBAR listing both foreign accounts, even if your combined balance on December 31 was only €3,000. Notice that the euro total (€9,500) never reached 10,000. The test is in dollars, not euros.

Which accounts count for FBAR? Wise, Revolut, PayPal, pensions and crypto

FBAR covers far more than ordinary bank accounts. Reportable accounts include foreign bank, securities and brokerage accounts, mutual funds, and cash-value insurance or annuities, and foreign pensions are generally reportable too, according to Taxes for Expats.

Account type	Reportable on FBAR?	What to check
Local bank checking or savings	Yes	Highest balance during the year
European brokerage or mutual fund account	Yes	Highest market value
Wise, Revolut, N26, PayPal and similar	Yes if the legal entity is outside the US	Legal entity in your terms and the IBAN country code
Cash-value life insurance or annuity	Yes	Cash value
Foreign pension (private or workplace)	Generally yes	Balance, or another method for defined-benefit plans
State pension (social security)	Generally no	Confirm the scheme is government social security, not an occupational plan
Foreign crypto exchange holding only virtual currency	Not currently	Becomes reportable if it also holds fiat or other reportable assets
US bank or brokerage account	No	Does not count toward $10,000

Wise, Revolut, PayPal and other fintech accounts

For fintechs, the legal entity decides whether the account is foreign, not the currency. Taxes for Expats says non-US-entity accounts such as Wise or Revolut Bank UAB are reportable if the entity is located outside the US, even if the account holds dollars. Check which company holds your account in the app's legal terms and look at your IBAN: one starting with LT, DE, BE or another non-US country code points to a foreign institution.

PayPal accounts are treated the same way: what matters is whether the account sits with a non-US PayPal entity, such as PayPal (Europe) in Luxembourg, so check your user agreement, as NSKT Global explains. If you are still choosing where to bank, our guide to foreigner banking restrictions in Europe explains why many Americans end up with fintech accounts in the first place.

Foreign pensions

Foreign pensions are generally reportable. For defined-benefit pensions with no account balance, the Taxes for Expats Help Center suggests reporting total distributions received as the highest value; with no distributions, report the cash surrender value or mark the maximum value as unknown. This is one practitioner's approach, so get advice if your pension is large or unusual.

Entitlements under government social security systems, such as Spain's Seguridad Social or Germany's Deutsche Rentenversicherung, are generally not treated as foreign financial accounts because you have no account balance you own or control. Private, workplace and occupational pensions are different and usually are reportable. If you are unsure which kind you have, ask a US tax adviser. For background, see our guide to expat pension plans in Europe.

Crypto

Under FinCEN Notice 2020-2, foreign accounts holding only virtual currency are not currently reportable on the FBAR, according to Taxes for Expats. If your foreign exchange account also holds euros or other fiat, the account becomes reportable.

What exchange rate do you use for FBAR?

You use the Treasury Reporting Rate of Exchange for December 31 of the year you are reporting, applied to each account's maximum value. The IRS Internal Revenue Manual says you do not use the IRS yearly average rate or the rate on the day your balance peaked. Treasury publishes these rates quarterly through the Bureau of the Fiscal Service.

So for your 2026 FBAR, you wait for the December 31, 2026 rate and apply it to every euro, pound or krone maximum. One rate per currency, used for all accounts in that currency, keeps your numbers consistent.

If Treasury publishes no rate for your currency, use another verifiable exchange rate for December 31 and note its source in your records, as the FinCEN FBAR Line Item Filing Instructions describe.

If you truly cannot work out whether your accounts crossed $10,000 and you have fewer than 25 accounts, FinCEN's instructions on reporting maximum account value say to complete the account section for each one and tick the "amount unknown" box, Item 15a. Use this only when you genuinely cannot get the figure.

How to file the FBAR electronically, step by step

You file the FBAR online through FinCEN's BSA E-Filing System, individuals do not need to register, and filing it yourself is free. The FinCEN FBAR Help guide says the FBAR is not filed with the IRS or with Form 1040, there is no downloadable paper form, and paper filing requires an exemption from FinCEN.

Before you start, gather for each account: the institution's name and address, the account number, the account type and the maximum value in dollars. Some of FinCEN's step-by-step guides are several years old, so the screens may look a little different from the descriptions below.

Go to the BSA E-Filing System and choose the option to file an FBAR as an individual without registration. Registration with a User ID and password is required only for institutions such as attorneys, CPAs and enrolled agents.
Pick your format. FinCEN's guide to filing the FBAR using the Online form says you can use the browser-based Online form, which does not need Adobe Reader, or the Adobe-enabled PDF form. The Online form cannot save your progress, so have every account's details ready and finish in one sitting. If you have many accounts or expect interruptions, the PDF form lets you save and come back.
Enter a Filing Name so you can recognize the report later. FinCEN's example in its guide on how to file the FBAR electronically is "Smith FBAR 2013". Something like "Garcia FBAR 2026" works.
Complete your filer information: the calendar year you are reporting, your name, taxpayer identification number, date of birth and address. Your European address is fine.
Add each account. Separate sections cover accounts you own alone, joint accounts, accounts you have signature authority over but no financial interest in, and a few less common cases. Fill in every required field (marked with an asterisk on the Online form and highlighted in yellow on the PDF).
Enter maximum values in US dollars, rounded up to the next whole dollar, using the December 31 Treasury rate.
Review, sign and submit. On the confirmation page, click Download Copy of My FBAR and save the confirmation page too. The read-only copy is for your records only and cannot be reused to amend.
Watch for the acknowledgement email. About two business days after filing, you should get an email with a BSA Identifier. Keep it as your proof of filing.

Can a married couple file one FBAR?

Sometimes. The FinCEN FBAR Line Item Filing Instructions say a spouse can skip a separate FBAR only if all of that spouse's reportable accounts are jointly owned with the filing spouse. The filing spouse must report those accounts on a timely, electronically signed FBAR, and both spouses must complete and sign Form 114a and keep it.

If the non-filing spouse has even one reportable foreign account that is not jointly owned with the filing spouse, that spouse must file their own FBAR. The filing spouse having a separate account of their own does not, by itself, require a second FBAR.

A joint account with a non-US spouse is still a foreign account you have a financial interest in, so it goes on your own FBAR. Report the full maximum value of the joint account, not just your share, and count the full value toward the $10,000 total.

Using a tax professional

If a CPA or enrolled agent files for you, you sign FinCEN Form 114a, the Record of Authorization to Electronically File FBARs. FinCEN says you do not send the 114a to FinCEN; you keep it with your records.

FBAR deadlines and penalties in 2026 and 2027

The FBAR for calendar year 2026 is due April 15, 2027, with an automatic extension to October 15, 2027, and you do not need to request it. The FBAR for 2025 was due April 15, 2026, and its extended date of October 15, 2026 has now passed, according to Taxes for Expats. Sources call the October date an extension or a grace period, but all agree that filing by October 15 counts as on time.

Penalty amounts

As of October 2026, the maximum civil FBAR penalty is $16,536 for a non-willful violation and the greater of $165,353 or 50% of the account balance for a willful violation, according to Virtue CPAs. These amounts did not rise for 2026. The Federal Register reports that OMB memo M-26-11 announced no 2026 cost-of-living multiplier because October 2025 CPI-U data was not produced during the government shutdown, so agencies kept the 2025 amounts.

Since the Supreme Court's 2023 decision in Bittner v. United States, the non-willful penalty applies per annual report, not per account. A missed FBAR with eight accounts is one violation, not eight. Willful penalties were not addressed and are generally applied per account, per year.

If you missed past FBARs

The path for catching up is less clear than it used to be. The IRS removed its Delinquent FBAR Submission Procedures webpage on July 1, 2026 without an announcement, according to EY Tax News. The related Internal Revenue Manual section reportedly remains, and Kaufman Rossin takes the view that relief survives there, while other practitioners say it can no longer be relied on.

If you also missed US tax returns or left foreign income off a return, the IRS now points people to the Streamlined Filing Compliance Procedures. These cover non-willful filers and generally mean three years of returns plus six years of FBARs. The version for people living abroad is the Streamlined Foreign Offshore Procedures. The program is discretionary and could change, so confirm the current terms on IRS.gov before relying on it.

Either way, treat the situation as unsettled. If you missed years by honest mistake, write down why (for example, you did not know the rule applied to a Revolut account), gather your old statements and speak with a US tax professional before filing late reports.

Separately, keep records for five years from the FBAR due date: account name and number, the institution's name and address, the account type and the maximum value, as CPA Training Center notes.

FBAR vs Form 8938: do you need both?

FBAR and Form 8938 are separate filings with different thresholds, and many Americans in Europe owe the FBAR but not Form 8938. Form 8938, the FATCA form, goes to the IRS with your Form 1040, while the FBAR goes to FinCEN.

Feature	FBAR (FinCEN Form 114)	Form 8938 (FATCA)
Filed with	FinCEN, BSA E-Filing System	IRS, attached to Form 1040
Threshold	Over $10,000 aggregate at any time, for everyone	Higher, and depends on where you live and your filing status
Single filer living abroad	$10,000	$200,000 at year-end or $300,000 at any time
Single filer living in the US	$10,000	$50,000 at year-end or $75,000 at any time

The IRS sets out these thresholds in its comparison of Form 8938 and FBAR requirements. Thresholds for married couples filing jointly are higher, so check the figures for your own filing status. If your foreign accounts, funds and other assets reach those levels, you may need both forms. If you are building a European portfolio, our guides on step by step investing in Europe and Europe mutual funds for beginners are worth reading with these reporting rules in mind.

Common mistakes

Most FBAR problems come from a handful of predictable errors. These are the ones that catch Americans in Europe most often:

Using the December 31 balance. The test uses each account's highest value during the year.
Testing each account alone. Two accounts at $6,000 and $5,000 trigger a filing.
Counting in euros. €9,500 can be more than $10,000. Convert first.
Using the wrong exchange rate. Use the Treasury December 31 rate, not the average rate or the rate on the peak day.
Reporting half of a joint account. Report the full maximum value.
Forgetting fintechs. A Wise, Revolut or PayPal account held by a non-US entity is foreign even if it holds dollars.
Skipping workplace pensions and insurance. Occupational pensions and cash-value policies are often missed.
Thinking no tax means no FBAR. The Foreign Earned Income Exclusion does not remove the FBAR requirement.
Mailing it to the IRS. The FBAR is filed online with FinCEN, not with your tax return.
Losing the BSA Identifier email. Save it with your statements for at least five years.

Frequently asked questions

What is FBAR in simple terms?

FBAR is the Report of Foreign Bank and Financial Accounts, filed as FinCEN Form 114. It tells the US Treasury about accounts you own or can sign on outside the United States. US persons must file it when the combined highest values of their foreign accounts exceeded $10,000 at any time during the year. It is a report only, so filing it does not by itself create a tax bill.

Do I need to file FBAR if less than $10,000?

No, if the sum of the highest values of all your foreign accounts stayed at or below $10,000 for the entire calendar year. Yes, if the total went over $10,000 even for one day, including a short spike from a house purchase or a large transfer. Add every foreign account together, ignore US accounts, and convert foreign currency using the Treasury December 31 exchange rate.

Is the FBAR filed with my tax return?

No. The FBAR is filed separately and electronically through FinCEN's BSA E-Filing System, not with the IRS or your Form 1040. Filing it yourself is free, and individuals can file without registering, using either a browser-based Online form or an Adobe-enabled PDF. There is no downloadable paper form. You should receive an acknowledgement email with a BSA Identifier within about two business days.

Do Wise and Revolut count for FBAR?

Usually, if the account is held by a company located outside the US. The legal entity decides whether the account is foreign, not the currency, so a dollar balance at a non-US Wise or Revolut entity still counts. PayPal works the same way. Check the legal entity named in your account terms and the country code at the start of your IBAN, then include the account in your $10,000 total.

When is the FBAR due for 2026 accounts?

As of October 2026, the FBAR covering calendar year 2026 is due April 15, 2027. An automatic extension to October 15, 2027 applies, and you do not need to request it or file anything to get it. The 2025 FBAR deadline, including its October 15, 2026 extension, has already passed. If you missed it, talk to a US tax professional about late filing.

What happens if I missed FBARs in past years?

You could face penalties, with the 2026 maximum non-willful penalty at $16,536 per annual report. The IRS removed its Delinquent FBAR Submission Procedures webpage on July 1, 2026, and practitioners disagree on whether that relief survives. If you also missed tax returns or income, the IRS points people to the Streamlined Filing Compliance Procedures. Document what happened and get professional advice before filing late.

References

Filed under Expat Finance & Investing Banking & Taxes

Muhammad Sahil

Founder and editor of EU Info Hub. Digital marketer with over seven years of freelance experience, now studying economics and business in Europe. He has been through the residence permit process himself. This article is general information, not legal or financial advice. Always confirm details with the relevant consulate or authority.