Form 8938 vs FBAR Threshold: The Numbers by Filing Status and Residence

The Form 8938 vs FBAR threshold comparison is lopsided: the FBAR applies once your foreign accounts together exceed $10,000 at any time in the year, whoever you are, while Form 8938 for an unmarried American living in the UK starts at more than $200,000 on December 31 or $300,000 at any time. Married couples, separate filers and people living in the US each have their own Form 8938 figures.

Most people who hold UK accounts cross the FBAR line years before they get near Form 8938, and then assume the higher number applies to both. It does not. This guide gives every threshold for tax year 2025 in one place, in dollars and in pounds, and then covers the three things that move people from one row of the table to another: the presence abroad test, how joint assets are counted, and how pensions are valued. For what each form actually covers, see our main comparison of Form 8938 vs the FBAR.

The Form 8938 vs FBAR threshold, side by side

The figures below come from the IRS Instructions for Form 8938 and the IRS FBAR page. The pound figures are approximate, converted at the Treasury Reporting Rate of Exchange for December 31, 2025 of 0.743 pounds per dollar, which is the rate both forms use for the 2025 year.

Form 8938 is triggered if either of its two tests is met: the year-end value or the value at any time during the year. The FBAR threshold does not change with marriage. Each US spouse applies the $10,000 test to their own accounts, including the full value of any joint account, although spouses who both have to file can in some cases combine their joint accounts on one report.

Why does the FBAR threshold not change with where you live?

The FBAR comes from the Bank Secrecy Act, not the tax code, and its threshold is written as a single figure for every US person. The IRS states that a US person must file if the aggregate value of their foreign financial accounts exceeded $10,000 at any time during the calendar year. The test uses the sum of each account's highest balance, converted at the year-end Treasury rate, so it is crossed more easily than the figure suggests; our guide to which UK accounts count toward FinCEN Form 114 shows the arithmetic, and our explainer on what FBAR reporting is covers why it exists.

Form 8938, by contrast, is the FATCA form and is filed as part of your income tax return. Its thresholds were set higher for people living abroad because nearly all of their financial life is necessarily foreign.

Who counts as living abroad for the higher Form 8938 thresholds?

The instructions set two conditions. Your tax home must be in a foreign country, and you must meet one of two presence abroad tests:

1. Bona fide residence. A US citizen who has been a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year.
2. Physical presence. A US citizen or resident who is present in a foreign country for at least 330 full days during any 12-month period ending in the tax year.

Two groups get caught out. The first is people in the year of a move: an American who arrived in London in June 2025 may not meet either test for 2025 and would then be held to the much lower US-resident thresholds. The second is green card holders. The bona fide residence route is available only to US citizens, so a green card holder living in the UK reaches the higher thresholds only through the 330-day test. Our page for green card holders explains the wider position.

How joint accounts change the Form 8938 vs FBAR threshold test

Joint assets are where the two forms differ most in practice, and where mixed US/UK couples most often get the Form 8938 test wrong. The Form 8938 instructions set three rules:

• Married filing jointly: a jointly owned asset is counted once, at its full value, on one combined Form 8938.
• Both spouses are US taxpayers filing separately: each spouse includes one-half of the value of the joint asset when testing the threshold.
• Joint owner is a spouse who is not a specified individual, or anyone else: each joint owner includes the entire value of the asset.

The third rule is the one that matters for an American married to a British partner with no US status. The non-American spouse is not a specified individual, so the American counts every joint account and every jointly owned investment at full value, even though half of the money is legally the spouse's. For the FBAR, the IRS FBAR Reference Guide likewise says each US owner of a joint account reports its entire value. Our guide to tax planning for mixed US/UK couples covers the filing status choice itself.

Illustrative example: an American in Bath is married to a British spouse and files as married filing separately. On December 31, 2025 she holds a joint savings account of £80,000 and a joint current account of £20,000 with her husband, a stocks and shares ISA of £40,000 and a SIPP valued at £30,000. Counting half of the joint accounts gives £120,000, about $161,508 at the year-end rate, which is below the $200,000 threshold. But her husband is not a specified individual, so the joint accounts count in full: £170,000, about $228,803. She files Form 8938 as well as the FBAR.

Which assets count toward each threshold?

The FBAR counts foreign financial accounts only. Form 8938 counts specified foreign financial assets, which include foreign accounts but also assets held outside an account, such as shares in a UK company held in your own name. According to the IRS comparison of Form 8938 and FBAR requirements, directly held foreign stock and foreign partnership interests go on Form 8938 but not the FBAR, while both forms include deposit and custodial accounts, foreign mutual funds and cash-value insurance. Neither form covers directly owned UK property or the UK State Pension.

Two Form 8938 counting rules are easy to miss:

• Assets on other forms still count. The instructions say you must include the value of assets reported on Forms 3520, 3520-A, 5471, 8621 and 8865 in determining whether you meet the threshold, even though you do not repeat their details on Form 8938. UK funds reported on Form 8621 as PFICs therefore still push you toward the threshold.
• Pensions have a fallback valuation. If you do not know, and have no reason to know from readily accessible information, the fair market value of your interest in a foreign pension plan, the instructions say to use the value of distributions received during the year, or zero if there were none. In practice, an annual pension statement showing a fund value is usually treated as readily accessible information, so that value is used. Our guide to SIPP US tax reporting covers pensions on both forms.

What people get wrong about the two thresholds

• Applying the $200,000 figure to the FBAR. The living-abroad thresholds belong to Form 8938 only. The FBAR stays at $10,000.
• Counting half of a joint account with a non-American spouse. For both forms the American counts it in full.
• Assuming the higher Form 8938 thresholds apply in the year of the move. They require a foreign tax home and one of the presence abroad tests.
• Skipping Form 8938 because the FBAR was filed. The Form 8938 instructions say filing Form 8938 does not relieve you of the FBAR requirement, and the FBAR does not satisfy Form 8938 either.
• Filing Form 8938 without a return. The instructions say that if you do not have to file an income tax return for the year, you do not have to file Form 8938, whatever your assets are worth. The FBAR has no such exception.

How to test both thresholds for 2025

1. List every UK account and asset you or your children held in 2025, including pensions, ISAs, joint accounts and directly held shares.
2. Test the FBAR: take each account's highest 2025 balance, convert at the December 31, 2025 Treasury rate, and add them up. More than $10,000 means you file FinCEN Form 114.
3. Find your Form 8938 row: confirm your filing status and whether you had a foreign tax home and met a presence abroad test for 2025.
4. Test Form 8938: total your specified foreign financial assets at year end and during the year, applying the joint-ownership rules above, and compare with your row of the table.
5. File accordingly: the FBAR with FinCEN, by October 15, 2026 under the automatic extension for the 2025 year; Form 8938 attached to your 2025 Form 1040 by its due date, including extensions.

Our guide to the FATCA reporting threshold in 2026 goes further into the Form 8938 side, including penalties.

Getting both thresholds right

For many Americans in the UK the FBAR is required every year and Form 8938 arrives later, as savings and pensions grow or when a joint account with a British spouse is counted correctly for the first time. Checking both tests each year, rather than relying on last year's answer, is what keeps the filings consistent.

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 FBAR and foreign asset reporting service tests both thresholds for you, values pensions and joint assets under the right rules, and files the FBAR and Form 8938 alongside your US return. Our overview for Americans in the UK covers the rest of the annual cycle, and you can contact us for a fixed quote.