FBAR Requirements for Expats: Joint Accounts, Pensions and Signature Authority

The FBAR requirements for expats go beyond accounts in your own name: a US person files FinCEN Form 114 when the foreign accounts they own, co-own or can sign on together exceed $10,000 at any time in the year. Joint accounts count in full, most UK pensions with a pot count, and an account you merely control counts too.

The basic rule, the threshold arithmetic and the filing mechanics are covered in our guides to what FBAR reporting is and which UK accounts count toward FinCEN Form 114. This article takes the three situations Americans abroad most often misreport: accounts shared with a spouse, pensions, and accounts that belong to someone else. Every rule below was checked on October 1, 2026 against FinCEN's FBAR Line Item Filing Instructions and the IRS FBAR Reference Guide (Publication 5569).

What are the FBAR requirements for expats, in one paragraph?

A United States person must file an FBAR if they have a financial interest in, or signature authority over, foreign financial accounts whose aggregate value exceeds $10,000 at any time during the calendar year. A financial interest exists when you are the owner of record or hold legal title, whether the account is for your benefit or someone else's. Signature authority exists when you can control what happens to the assets by communicating directly with the institution.

Both kinds of account go into the same $10,000 test. The report for calendar year 2025 was due April 15, 2026, and the IRS confirms an automatic extension to October 15, 2026 with no request needed. See our FBAR deadline guide.

How do the FBAR requirements for expats treat joint accounts?

Each US person who jointly owns a foreign account reports the entire value of that account, not a share of it. The regulation, 31 CFR 1010.350, says that where an account is maintained in the name of more than one person, each US person named has a financial interest in it. FinCEN's instructions for Part III add that each joint owner must report the entire value.

Joint accounts with a non-American spouse

The American spouse reports the joint account in Part III at its full maximum value, and the whole balance goes into the $10,000 test, even if the British spouse paid in every pound. The British spouse files nothing.

Three details from the Part III instructions help here:

• Item 24, number of joint owners, does not count the filer. For an account held with one spouse, the answer is 1.
• Items 25 to 33 identify the principal joint owner. Where a spouse has an interest in the account, the instructions say the spouse is the principal joint owner.
• The spouse's taxpayer identification number is requested "if known." A British spouse will often have no US number, and the instructions say to leave blank any item for which no information is available.

Form 114a plays no part in this case, because only one person is filing. The full-value rule also applies to Form 8938, as our guide to the Form 8938 and FBAR thresholds explains, and it feeds into tax planning for mixed US/UK couples.

When both spouses are American: the spouse exception and Form 114a

FinCEN's instructions allow one FBAR to cover both spouses when three conditions are all met:

1. All the financial accounts the non-filing spouse is required to report are jointly owned with the filing spouse.
2. The filing spouse reports the jointly owned accounts on a timely filed, electronically signed FBAR.
3. Both spouses have completed and signed Form 114a, the Record of Authorization to Electronically File FBARs, which is kept with their records and not sent to FinCEN.

The first condition is where American couples in the UK fail. GOV.UK states that you cannot hold an ISA with someone else, and a pension pot belongs to one member. A spouse who holds a single ISA or workplace pension has an account that is not jointly owned with the filer, so the exception is unavailable: both spouses file separate FBARs and each reports the entire value of the joint accounts.

Which UK pensions are reportable on the FBAR?

A UK pension is reportable when it is a foreign financial account in which you have a financial interest and no exception applies. The retirement exceptions in FinCEN's instructions cover only an IRA and a retirement plan described in Internal Revenue Code section 401(a), 403(a) or 403(b). The IRS Reference Guide gives the Canadian RRSP and Mexican AFORE as examples of foreign retirement accounts that are reportable.

• SIPPs and personal pensions. You hold an account with a provider in your own name. These are reported in Part II as separately owned accounts. Our guide to SIPP US tax reporting covers the other forms.
• Workplace defined-contribution schemes. A group personal pension is a contract between you and the provider and is treated like a personal pension. A trust-based scheme is different in form: the trustees hold legal title. When FinCEN finalized the rules in 2011, its Federal Register preamble declined a blanket exemption for other pension plan members and told participants outside the exemption to look to the 50 percent ownership tests. Because a defined-contribution member has an identified pot with a stated value, the cautious and common approach is to report it rather than rely on a technical reading. Our guide to the UK workplace pension for a US citizen covers the tax side.
• Defined-benefit schemes. A final salary or career average scheme promises an income; there is no account balance in your name, and a member of a large scheme is nowhere near a 50 percent interest in the trust. FinCEN's instructions do not address UK defined-benefit schemes by name and practice among advisers differs. Decide this one scheme by scheme, with advice, and apply the answer consistently.
• The UK State Pension. The IRS comparison of Form 8938 and FBAR requirements lists social security-type program benefits provided by a foreign government as not reportable on either form.

What value do you use for a pension?

The FBAR asks for the maximum value of the account during the calendar year, which FinCEN's instructions describe as a reasonable approximation of the greatest value of the assets in it. Periodic statements may be relied on if they fairly reflect that maximum. For a pension that means the highest value shown on the provider's statements or online valuations for the year, not the amount you could withdraw. Convert at the Treasury's year-end rate and round up to the next whole dollar, as the instructions require.

The FBAR has no fallback valuation for pensions. Form 8938 does, which is one of the differences set out in our comparison of the FBAR and Form 8938. Our US/UK pensions service deals with the tax treatment behind the reporting.

What counts as signature authority without a financial interest?

Signature authority is the authority of an individual, alone or with someone else, to control the disposition of assets in an account by direct communication with the institution that holds it. In the 2011 preamble, FinCEN put the test in practical terms: would the foreign bank act on a direct communication from you? Dual-signatory arrangements are covered too. Taking part in the decision, or supervising the person who instructs the bank, is not the test.

Employer accounts

A finance manager or director who can release payments from a UK company's bank account has signature authority over it. The exceptions in the regulation cover officers and employees of banks examined by the US banking regulators, of financial institutions registered with and examined by the SEC or CFTC, of certain service providers to SEC-registered investment companies, of entities with equity securities listed on a US national securities exchange or registered under section 12(g) of the Securities Exchange Act, and of US subsidiaries included in a US-listed parent's consolidated FBAR. Each applies only where the individual has no financial interest in the account.

An employee of a UK private company, or of a company listed only in London, fits none of these. Two forms of relief do exist:

• Shorter reporting for people who live and work abroad. FinCEN's instructions say a US person who resides outside the US, is an officer or employee of an employer physically located outside the US, and has signature authority over that employer's account completes only Part I and Items 34 to 43 of Part IV, once, with the employer's details.
• A deferred due date for some. FinCEN Notice FIN-2025-NTC3, dated December 8, 2025, extends to April 15, 2027 the filing date for certain individuals with signature authority only whose deadline was extended by earlier notices, including for authority held during 2025. The notices are aimed at officers and employees connected to the regulated and listed entities above; for everyone else the notice states that the due date remains April 15, 2026.

Charity, club and society treasurers

A volunteer treasurer who is a signatory on a UK charity's, sports club's or school association's bank account has signature authority over it. No exception refers to charities. FinCEN's preamble records requests for wider relief, including for tax-exempt colleges, and explains that tax-exempt status does not remove the need for the report. The account is reported in Part IV with the organization as owner and "Treasurer" as the filer's title in Item 43. The balance counts toward the $10,000 test.

A parent's accounts under a power of attorney

The IRS Reference Guide uses this exact example: Megan, a US resident, holds a power of attorney over her elderly parents' accounts in Canada and has never used it. She must file if the power of attorney gives her signature authority over the accounts, and whether she ever exercised it is irrelevant. In England and Wales, GOV.UK explains that a property and financial affairs lasting power of attorney can cover managing a bank or building society account and can be used as soon as it is registered, with the donor's permission.

Being added to a parent's account as a joint holder is different. That makes you an owner of record, so the account goes in Part III at full value.

Children's accounts and Junior ISAs

FinCEN's instructions define a United States person to include minor children who are citizens, and state that a child is generally responsible for filing their own FBAR. If the child cannot file because of age, the parent, guardian or other legally responsible person must file it, signing with the title "Parent/Guardian filing for child."

A Junior ISA is the usual trigger. GOV.UK says parents or guardians can open and manage a Junior ISA but the money belongs to the child, and gives the savings limit for the 2026 to 2027 tax year as £9,000. A few years of subscriptions can take a child past $10,000.

Whether the American parent who manages the account must also report it as signature authority is not answered by name in the instructions. The test is the usual one: will the provider act on the parent's direct instruction about the assets? Where it will, the cautious course is to report the account in Part IV. See our page for cross-border families.

Illustrative example: an American in Leeds is married to a British spouse and has a US citizen daughter. For 2025 her highest balances were a joint current account at £9,000, her own cash ISA at £4,000 and a SIPP at £38,000. At the Treasury year-end rate of 0.743 pounds per dollar, and rounding up, she reports $12,114 in Part III and $5,384 and $51,145 in Part II. As finance manager of a UK private company she can also release payments from its bank account, so she completes Items 34 to 43 of Part IV with her employer's details. Her daughter's Junior ISA peaked at £11,000, about $14,805, so the daughter has her own FBAR, which a parent files and signs.

Do I report it? A decision table

What records must you keep?

Anyone required to file must keep, for each account, the name it is held in, the account number, the name and address of the foreign institution, the type of account and its maximum value in the year. FinCEN's instructions set the period at five years from April 15 of the year following the calendar year reported, or from the date filed if later. A copy of the filed FBAR helps satisfy the rule.

There is one relief: an officer or employee who files to report signature authority over an employer's account is not required to personally retain records of that account. The relief is worded for employers' accounts, so a volunteer treasurer or family attorney should keep the five items themselves.

Getting the hard cases right

For a first filing, our guides to filing an FBAR for the first time and to filing the FBAR online take you through the form itself. If earlier years are missing because a pension, a joint account or a signature-authority account was left off, read our guide to the Streamlined Foreign Offshore Procedures before filing anything late.

US/UK Cross Border Tax is a team of US CPAs and UK tax advisers working as one team, in London, Manchester, New York and San Francisco. Our foreign account reporting service applies the FBAR requirements for expats to your actual accounts: we sort each one into owned, joint or signature authority, settle how each pension is treated, prepare a child's report where one is needed, and file alongside your US return. You can contact us for a fixed quote.