FATCA Reporting Threshold 2026: Form 8938 Limits for Americans Living Abroad

The FATCA reporting threshold 2026 filers need is the Form 8938 test for tax year 2025: an unmarried American living abroad files if specified foreign financial assets exceeded $200,000 on December 31, 2025 or $300,000 at any time in 2025. Married couples filing jointly abroad use $400,000 and $600,000. Americans living in the US face thresholds one quarter of those amounts, and the figures are not indexed, so they apply unchanged to tax year 2026.

This guide is about the threshold question only: which number applies to you, what goes into the total, and how to turn pounds into dollars the way the IRS expects. If you want the wider picture of how Form 8938 sits next to the FBAR, start with our guide to FBAR vs Form 8938 and come back here to test your own numbers.

What does "2026" mean for the FATCA reporting threshold?

The "2026" label almost always refers to the return you file during 2026, which reports tax year 2025. Form 8938 is attached to Form 1040 and is due with it, including extensions, so the assets you test are the ones you held during calendar year 2025.

The IRS confirms on its automatic 2-month extension page that a US citizen living outside the US on the regular due date gets until June 15 to file, with interest running on any unpaid tax from April 15. A Form 4868 extension carries the tax year 2025 return, and the Form 8938 attached to it, to October 15, 2026. If you are working toward that date now, our guide to the US expat tax extension deadline for 2026 covers the steps.

The thresholds themselves do not move from year to year. The IRS page on who must file Form 8938, last reviewed in September 2026, shows the same dollar amounts as the Instructions for Form 8938, which were last revised in November 2021 and remain the current version. Nothing on either page indexes the figures for inflation. So the same test applies to tax year 2025 (filed in 2026) and tax year 2026 (filed in 2027).

Form 8938 thresholds for tax year 2025: the decision table

There are two tests for every filing status: a last-day test on December 31 and an any-time test during the year. Exceeding either one triggers the filing requirement. The table below sets out every combination from the IRS instructions, with the pound equivalents at the Treasury rate for December 31, 2025.

The pound figures are a guide, not a safe harbor. Values that sit close to the line should be worked through account by account, because rounding and the choice of statement date can move you across it.

Who qualifies for the higher "living abroad" thresholds?

You qualify for the abroad thresholds only if you meet one of two tests in the Form 8938 instructions. Living in London with a UK address is not, by itself, enough.

• Bona fide residence: you are a US citizen whose tax home is in a foreign country and you are a bona fide resident of a foreign country or countries for an uninterrupted period that includes the entire tax year.
• Physical presence: you are physically present in a foreign country or countries for at least 330 full days during a period of 12 consecutive months ending in the tax year.

The tests matter most in the year you move. An American who arrived in the UK in September 2025 will usually not have 330 days abroad in a 12-month period ending in 2025, and cannot be a bona fide resident for the whole of 2025. That person tests against the US-resident thresholds of $50,000 and $75,000 for the 2025 return, even though they now live in Britain. The same logic applies in reverse to someone who moved back to the US during the year. These are the same residence tests used for the foreign earned income exclusion, so a return that claims the exclusion on Form 2555 and a Form 8938 that applies the abroad threshold should tell the same story.

What counts toward the Form 8938 threshold for UK residents?

Form 8938 counts "specified foreign financial assets", which is broader than the FBAR's list of accounts. For an American in the UK, the IRS comparison of Form 8938 and FBAR requirements and the instructions point to the following treatment.

Included in the total

• UK bank and building society accounts, including current accounts, savings accounts and fixed-term deposits.
• ISAs. A cash ISA is a financial account; a stocks and shares ISA is a financial account holding securities. The ISA wrapper has no US effect, and the funds inside are often PFICs, which our guide to ISAs and PFIC rules explains.
• Workplace pensions and SIPPs. The instructions tell you to report your interest in a foreign pension plan and not to report the assets held by the plan separately. Our guide to SIPP reporting on a US return covers the wider tax picture.
• UK shares held directly, for example on a paper certificate or through an employee share plan outside a brokerage account. Foreign stock not held in a financial account is reportable on Form 8938 but not on the FBAR.
• Interests in UK companies and partnerships, such as shares in your own UK limited company.
• Foreign-issued life insurance or annuity contracts with a cash value.

Left out of the total

• UK property held directly. The IRS comparison page lists directly held foreign real estate as not reportable on either form. Property held through a UK company is different, because the company shares are a specified foreign financial asset.
• The UK State Pension. The instructions exclude payments or rights to receive the foreign equivalent of US social security.
• Accounts at US institutions, including a US brokerage account that holds UK shares, and a US branch of a foreign bank. An account maintained by a US payer is not reportable.

One point catches people out: assets you report on another form, such as Form 8621 for a PFIC or Form 5471 for a UK company you control, can be left off the detailed Form 8938 schedules, but the instructions say you must still include their value when testing the threshold and list those forms on Form 8938.

How do you convert pounds to dollars for Form 8938?

You convert each asset's maximum value to dollars at the US Treasury Bureau of the Fiscal Service exchange rate for the last day of the tax year. The Form 8938 instructions apply that year-end rate even when the maximum value was reached months earlier. For tax year 2025, the Treasury Reporting Rates of Exchange dataset shows 0.743 pounds per dollar on December 31, 2025. To convert, divide the pound amount by 0.743.

1. List every specified foreign financial asset you held at any point in 2025, including accounts you closed during the year.
2. Find the year-end value of each on December 31, 2025, from your statements. A pension provider's annual statement is usually the practical source.
3. Find the maximum value of each during 2025. The instructions let you rely on periodic account statements unless you know they do not reflect a reasonable estimate.
4. Convert both figures at 0.743 pounds per dollar, the Treasury rate for December 31, 2025.
5. Add the year-end values and compare with the last-day threshold for your status. Then add the maximum values and compare with the any-time threshold.
6. If either total exceeds its threshold, you file Form 8938 with your tax year 2025 return and report every specified foreign financial asset, not only the large ones.

A negative value is treated as zero. If you do not know the year-end value of a pension interest and cannot find it from readily accessible information, the instructions let you use the value of cash and property distributed to you during the year instead, which for someone not yet drawing a pension may be zero. Use that fallback only when the provider genuinely cannot give you a figure.

Illustrative example: an unmarried American who has lived in Manchester since 2019 holds, on December 31, 2025, £40,000 in a current account, £70,000 in a stocks and shares ISA and a workplace pension valued at £60,000. The total is £170,000, which divided by 0.743 is about $228,800. That exceeds the $200,000 last-day threshold, so Form 8938 is required with the 2025 return even though no single asset comes close to it. Had the same person moved to the UK in August 2025, the US-resident threshold of $50,000 would apply for that year, and the answer would be the same with a much smaller balance.

How do joint accounts and married couples count?

Joint ownership changes the arithmetic, and the rule depends on how you file.

• Married filing jointly: the couple files one combined Form 8938 and counts a jointly owned asset once, at its full value, against the $400,000 and $600,000 abroad thresholds.
• Married filing separately, both spouses US persons: each spouse counts one half of a jointly owned asset when testing the threshold. If both end up filing, each reports the full maximum value of the joint asset on their own Form 8938.
• Married to a non-US spouse: the half-value rule applies only where both spouses are specified individuals. Otherwise the general rule applies and each joint owner counts the entire value of the asset. For many Americans married to Brits, that means a joint savings account counts in full against the $200,000 threshold.

This is one reason filing status deserves a proper look. A couple where only one spouse is American might choose married filing separately to keep the UK spouse out of the US system, but then the American spouse tests alone against $200,000 with joint assets counted in full. Our work for Americans in the UK starts with that choice for exactly this reason.

What do people get wrong about the Form 8938 threshold?

• Testing only the year-end figure. A house deposit that sat in a UK savings account for three months can push the any-time total over $300,000 or $600,000 even if the money was spent by December.
• Leaving out the pension. Workplace pensions and SIPPs are often the largest asset an American in the UK owns, and they count.
• Using the wrong rate. The FBAR and Form 8938 both use a year-end Treasury rate, but using a spot rate from the date of the peak balance can give a different answer near the line.
• Assuming the first year abroad uses the abroad thresholds. It often does not, because the residence tests are not met.
• Thinking the FBAR covers it. The FBAR goes to FinCEN and does not satisfy Form 8938. Our guide to FinCEN Form 114 covers that separate filing.

What happens if you miss Form 8938?

The Form 8938 instructions set the penalties. Failing to file a correct and complete Form 8938 carries a $10,000 penalty. If you have not filed 90 days after the IRS mails a notice, an additional $10,000 applies for each 30-day period the failure continues, up to a maximum of $50,000 more. Separately, a 40% penalty can apply to an underpayment of tax linked to an undisclosed specified foreign financial asset.

The instructions also say no penalty is imposed where the failure is due to reasonable cause and not willful neglect. There is a statute of limitations effect as well: if you leave out more than $5,000 of income from specified foreign financial assets, the IRS can assess tax for that year for six years instead of three. Where filings were missed, the fix-it route depends on whether income was also left off; our guide to the Streamlined Foreign Offshore Procedures covers the case where it was.

Getting the threshold test right

The FATCA test is simple on paper and fiddly in practice: two thresholds per status, a residence test that can switch you between the US and abroad figures, a fixed year-end exchange rate and a long list of UK assets that count. Our FATCA reporting threshold 2026 review runs each client's accounts, ISAs, pensions and shareholdings through both the Form 8938 and FBAR tests from one set of figures, then prepares the forms with the return. For PFIC holdings inside ISAs we add the Form 8621 work through our PFIC reporting service.

US/UK Cross Border Tax — US CPAs and UK tax advisers working as one team; London, Manchester, New York, San Francisco. If you are close to a Form 8938 threshold or unsure which one applies, contact us before the October 15, 2026 extended deadline.