FinCEN Form 114: Which UK Accounts Count Toward the $10,000 Threshold

FinCEN Form 114, the FBAR, is required when the combined maximum values of all your non-US financial accounts exceed $10,000 at any time in the calendar year. For an American in the UK that total usually includes current accounts, savings, cash and stocks and shares ISAs, UK funds and most pensions, each taken at its highest balance. The threshold is aggregate, not per account, and it is lower in pounds than most people assume.

Most questions about the FBAR are really one question: does this particular account count? This guide answers it account by account for the UK, shows how FinCEN's rules turn a handful of modest balances into a filing requirement, and flags the few places where the answer is genuinely unsettled. If you are new to the form itself, start with our guide to filing an FBAR for the first time, then come back here to build your account list.

What is FinCEN Form 114 and who has to file it?

FinCEN Form 114 is the Report of Foreign Bank and Financial Accounts. FinCEN's filing instructions say a United States person with a financial interest in, or signature authority over, foreign financial accounts must file if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year. The report goes to FinCEN through the BSA E-Filing System, and the IRS confirms that you do not file the FBAR with your federal tax return.

A United States person includes US citizens, including minor children, US residents, and US entities and trusts. Two points catch Americans in the UK. First, the FBAR comes from the Bank Secrecy Act rather than the tax code, so it applies whether or not you owe US tax. Second, the IRS FBAR Reference Guide states that tax treaties with the US do not affect FBAR filing obligations, so a treaty tie-breaker that makes you UK-resident for tax does not take you out of the FBAR.

For the 2025 calendar year the report was due April 15, 2026, with FinCEN's automatic extension to October 15, 2026 that nobody has to request. Our post on the FBAR deadline in 2026 covers the dates in detail.

How the $10,000 FBAR threshold is really calculated

The FBAR threshold is not a snapshot of your balances on one day. FinCEN's instructions set out two steps:

1. Find each account's maximum value in its own currency during the calendar year. The maximum value is a reasonable approximation of the greatest value of cash and assets in the account, and periodic statements may be relied on if they fairly reflect that maximum.
2. Convert each maximum to dollars using the Treasury Reporting Rates of Exchange for the last day of the calendar year, then round up to the next whole dollar. A negative value is entered as zero.

Then add the converted maximums together. If the single account maximum or the aggregate of all the maximums exceeds $10,000, you file, and every account is reported, however small. The IRS Reference Guide gives the example of accounts with maximums of $100, $12,000 and $3,000: all three are reported, not just the large one.

Two consequences follow. The first is that the maximums rarely coincide in time, so the aggregate can be far higher than your wealth was on any given day. If you moved £5,000 from a current account into a savings account in March, that £5,000 appears in both maximums. The second is that the dollar threshold translates into pounds at the year-end rate. The Treasury rate for December 31, 2025 is 0.743 pounds per dollar, so for the 2025 report the threshold is crossed once your combined UK maximums exceed roughly £7,430.

Illustrative example: an American teacher in Bristol has three UK accounts. The current account peaked at £4,200 in the month her salary and a tax refund landed together. An easy-access savings account peaked at £3,100 after she moved money into it in the autumn. A stocks and shares ISA peaked at £1,500. At the December 31, 2025 rate of 0.743, those maximums convert to $5,653, $4,173 and $2,019, a total of $11,845. She never held more than about £6,000 across all three accounts on any single day, yet she must file FinCEN Form 114 for 2025 and report all three accounts.

Which UK accounts count toward the FBAR threshold?

FinCEN defines a financial account broadly: a securities, brokerage, savings, demand, checking, deposit, time deposit or other account maintained with a financial institution, plus commodity futures or options accounts, insurance or annuity policies with a cash value, and shares in a mutual fund or similar pooled fund available to the public with a regular net asset value and regular redemptions. The table below maps that definition onto the UK products Americans most often hold.

Bank accounts, savings and ISAs

Every UK bank or building society account in your name counts, including dormant accounts, an old student account you never closed, and accounts that pay no interest. The IRS Reference Guide is explicit that whether an account produces income does not affect the filing requirement. An ISA is treated like any other account of its type: a cash ISA is a savings account and a stocks and shares ISA is a securities account. The ISA's UK tax exemption does not carry over to the US, and the funds inside a stocks and shares ISA raise a separate PFIC question that we cover in our guide to ISAs and PFIC tax.

Accounts with UK app-based banks and e-money providers are held with an institution performing the services of a financial institution, and are generally treated as reportable in the same way as a high-street account.

Investment accounts and UK funds

For a brokerage or platform account, the IRS comparison page says the account itself is reported and its contents do not have to be listed separately. You report one maximum value for the account, not a line for each fund. A UK fund held directly with the fund manager, outside a platform, is itself a foreign mutual fund, which the IRS comparison of Form 8938 and FBAR requirements lists as reportable on the FBAR. The location of the account decides the question, not the investments inside it: a US brokerage account holding UK shares is not a foreign account.

Pensions

This is where the most money sits and where the most mistakes are made. FinCEN's exceptions cover IRA owners and beneficiaries, and participants in and beneficiaries of retirement plans described in Internal Revenue Code sections 401(a), 403(a) and 403(b). Those are US plans. A UK pension is not one of them, and the IRS Reference Guide gives foreign retirement accounts, such as the Canadian RRSP, as examples of reportable foreign financial accounts. The practical result is that a SIPP or a defined contribution workplace pension usually counts toward your threshold, often by itself exceeding it. Our guide to SIPP US tax reporting takes the pension analysis further.

Defined benefit (final salary) schemes are harder, because a member has a promise of future income rather than an account with a balance. Practice differs on whether and how they are reported, and the answer depends on the scheme. That is a question to take to an adviser rather than to guess at.

Joint accounts and signature authority

If you hold a joint account with a British spouse, the whole balance goes into your total, not half. The IRS Reference Guide states that each US person with an interest in a jointly held account must report its entire value. Your spouse, if not a US person, has no FBAR requirement of their own.

Signature authority is the other surprise. FinCEN defines it as the authority to control the disposition of assets in an account by direct communication with the institution, alone or with someone else. If you can instruct payments from your employer's or your own company's UK bank account, you may need to report it even though none of the money is yours. The exceptions largely cover officers and employees of US-regulated banks and financial institutions and of companies with securities listed on a US exchange, so most employees of UK private companies fall outside them. The IRS Reference Guide adds that it does not matter whether you ever used the authority.

What does not count toward the FBAR threshold?

Some UK assets stay off FinCEN Form 114 entirely, according to the IRS comparison page: property you own directly, shares held in your own name rather than through an account, foreign currency or precious metals you hold physically, personal property, and foreign social security-type benefits such as the UK State Pension. Foreign hedge funds and private equity funds are also listed as not reportable on the FBAR. Under current regulations, the IRS Reference Guide says a foreign account holding only virtual currency is not reportable, although FinCEN has signaled an intention to change that.

Not reportable on the FBAR does not mean not reportable at all. Directly held shares and interests in foreign entities can belong on Form 8938, which has its own, higher thresholds. Our comparison of the FBAR and Form 8938 explains how the two forms overlap.

What people get wrong about FinCEN Form 114

• Testing each account separately. The threshold is aggregate. Three accounts of $4,000 each at their peaks means a filing requirement.
• Using year-end balances. The test uses the highest balance during the year. A December balance can be a fraction of a peak reached in a bonus month.
• Converting at the rate on the day of the peak. FinCEN requires the Treasury rate for the last day of the calendar year for every account, whenever its maximum occurred.
• Leaving out the pension. The retirement exceptions are for US plans. A UK pension usually counts.
• Reporting half a joint account. Each US owner reports the full value.
• Ignoring a child's accounts. A US citizen child with a Junior ISA or savings account over the threshold has an FBAR of their own, filed by a parent where the child cannot file.

How to build your FinCEN Form 114 account list

1. List every UK institution you or your children dealt with during the year, including closed and dormant accounts, pensions, insurers and fund managers, plus any business accounts you can sign on.
2. Find each account's maximum from statements. Where statements are at least quarterly and fairly reflect the peak, the IRS Reference Guide says you may rely on them; where a large payment went in and out between statements, check the transaction history.
3. Convert at the year-end Treasury rate and round each figure up to the next whole dollar.
4. Add them up. If the total exceeds $10,000, report every account, not only the large ones. If you have 25 or more accounts, the form has a shortened reporting option, but you must keep full records.
5. Keep the records for five years. FinCEN requires you to retain the name on each account, the account number, the institution's name and address, the account type and its maximum value, for five years from the April 15 due date.

The filing itself is then straightforward. Our walkthrough of how to file an FBAR online covers the BSA E-Filing System screen by screen.

If you should have filed in earlier years

Discovering that a pension or an ISA pushed you over the threshold in past years is common, and there are established routes to put it right. FBAR penalties are set by statute and adjusted for inflation, and the IRS Reference Guide explains that non-willful and willful failures are treated very differently. For most Americans in the UK who simply did not know, the Streamlined Foreign Offshore Procedures are the usual way to bring both returns and FBARs up to date. Get advice before filing late reports on their own, because the route you choose affects the outcome.

Getting FinCEN Form 114 right every year

For a couple of bank accounts, the arithmetic above is a job for an evening. It becomes a professional job when a pension or defined benefit scheme has no obvious value, when you hold signature authority over business accounts, when funds inside an ISA also need PFIC reporting, or when earlier years are missing.

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. We prepare and file FinCEN Form 114 alongside your US return: we identify which UK accounts count, calculate each maximum at the correct Treasury rate, and keep the records FinCEN requires. Our overview for Americans in the UK covers the rest of the annual cycle, and you can contact us for a fixed quote before the October 15 deadline.