What Is FBAR Reporting? A Plain-English Guide for Americans in the UK

What is FBAR reporting? It is the yearly disclosure of your non-US bank and financial accounts that the US Treasury requires of US citizens and residents, made on FinCEN Form 114 whenever those accounts together exceed $10,000 at any point in the calendar year. It is an information report, not a tax, and it is filed separately from your tax return.

For Americans in the UK the FBAR is often the first piece of US paperwork that feels out of proportion: no tax is due, the threshold is low, and the penalties can be severe. This guide explains what the report is for, who has to file it, how it relates to your tax return and to FATCA, and what happens if years have been missed. For the mechanics of filing, see our guide to filing an FBAR for the first time.

What is FBAR reporting?

FBAR reporting is the annual filing of the Report of Foreign Bank and Financial Accounts, FinCEN Form 114. The IRS FBAR Reference Guide explains that the Bank Secrecy Act gave the Treasury authority to collect information from US persons who have a financial interest in, or signature or other authority over, financial accounts held with institutions outside the United States. FinCEN Form 114 replaced the old paper Treasury Form TD F 90-22.1 and is now available online only, through the BSA E-Filing System.

Three agencies are involved, which is part of the confusion. The Treasury holds the legal power. The Financial Crimes Enforcement Network, FinCEN, receives the report. And the IRS enforces it: the Reference Guide records that in April 2003 FinCEN delegated FBAR enforcement authority to the IRS, which investigates possible civil violations, assesses and collects civil penalties, and issues administrative rulings.

The report itself is simple in content. For each account it lists the owner, the institution's name and address, the account number, the type of account and the maximum value during the year, converted to US dollars.

Why does the US government want to know about your UK accounts?

The FBAR exists because foreign banks are outside the reporting system that US banks sit in. The Reference Guide says that foreign financial institutions may not be subject to the same reporting requirements as domestic ones, and that the government uses the FBAR to identify people who may be using foreign accounts to circumvent US law, to trace funds used for illicit purposes, and to identify unreported income held or generated abroad.

That purpose explains two features that otherwise seem odd. The FBAR applies whether or not you owe any US tax, because it sits under Title 31 of the US Code, the Bank Secrecy Act, rather than Title 26, the Internal Revenue Code. And it applies to ordinary accounts that are obviously legitimate, such as the current account your salary is paid into, because the report is about visibility rather than suspicion.

Who has to do FBAR reporting?

A US person must file an FBAR when they have a financial interest in, or signature or other authority over, financial accounts outside the United States, and the aggregate value of those accounts exceeds $10,000 at any time during the calendar year. That is the rule set out on the IRS FBAR page.

• US citizens, wherever they live, including children and people who have never lived in the US.
• US residents, which includes green card holders. The Reference Guide gives the example of a UK citizen with a green card who is treaty-resident in the UK and is still a US person for FBAR purposes, because tax treaties do not affect FBAR filing obligations. Our page for green card holders covers the wider picture.
• US entities, trusts and estates that hold foreign accounts.

The $10,000 test is the part people misread. It is the sum of each account's highest balance in the year, not the total on any one day, and it covers far more than bank accounts: ISAs, investment accounts, UK funds and most pensions go into the total. Our guide to which UK accounts count toward FinCEN Form 114 works through the arithmetic account by account.

FBAR reporting compared with your tax return and FATCA

Americans in the UK meet foreign accounts in four separate places, and each has a different purpose, recipient and trigger.

The FBAR and Form 8938 overlap but do not replace each other, and many Americans in the UK file both; our comparison of the FBAR and Form 8938 sets out the differences, and our guide to the FATCA reporting threshold for 2026 gives the Form 8938 figures.

How does FBAR reporting connect to FATCA and your UK bank?

Your UK bank is very likely reporting you already. HMRC's International Exchange of Information Manual records that the UK and the US signed a treaty to implement FATCA on 12 September 2012, and that the UK regulations oblige UK financial institutions to identify, capture and report information to HMRC on financial accounts held by US citizens. HMRC's background note describes that information as collected for onward transmission. This is why UK banks ask new customers to self-certify their tax residence and citizenship.

The practical point is consistency. The IRS may hold bank-reported data about your UK accounts, your tax return answers a direct question about foreign accounts on Schedule B, and your FBAR lists them. The Reference Guide describes both the FBAR itself and the answers to those return questions as part of fulfilling the reporting requirement. When all three agree, there is nothing to explain. When an account appears in one place and not another, that is the kind of gap that prompts questions.

When is FBAR reporting due?

The FBAR is a calendar-year report due April 15 of the following year, and FinCEN grants every filer an automatic extension to October 15 without any request. For the 2025 calendar year that means the report was due April 15, 2026, extended automatically to October 15, 2026. The Reference Guide notes that before the 2016 reporting year the deadline was June 30 with no extension, so older guidance you find online may give the wrong date. Our post on the FBAR deadline in 2026 covers the dates, and our walkthrough shows how to file the FBAR online.

If some details are still missing near the deadline, the Reference Guide's advice is to file as complete a report as possible by October 15 and amend it when better information arrives, rather than miss the date.

What happens if you have not been doing FBAR reporting?

Most Americans in the UK who have missed FBARs did so because nobody told them, and the rules treat that very differently from deliberate concealment. The Reference Guide sets out the framework:

• Late filing with reasonable cause. A late FBAR is filed through the same BSA E-Filing System, with a field of up to 750 characters to explain the late filing. If the accounts are properly reported and the IRS decides the failure was due to reasonable cause, no penalty is imposed.
• Non-willful violations. The maximum civil penalty is an inflation-adjusted amount set in 31 CFR 1010.821, and there is no minimum. In Bittner v. United States, decided on February 28, 2023, the Supreme Court held that the non-willful penalty accrues per report, not per account. The case involved a dual citizen whose five late reports covered 272 accounts.
• Willful violations. The maximum civil penalty is the greater of the inflation-adjusted amount or 50 percent of the account balance at the time of the violation, and criminal penalties can apply as well.

Illustrative example: an American who moved to Edinburgh eight years ago has a UK current account, a cash ISA and a workplace pension, and has filed US tax returns but never an FBAR, because no one mentioned it. Her UK bank has had her down as a US person since she opened the account. Filing this year's FBAR alone would leave the missing years open. The usual route for someone in her position is the Streamlined Foreign Offshore Procedures, which bring the last six years of FBARs and the last three years of returns up to date together, with a certification that the failure was non-willful.

The IRS sets out the requirements on its Streamlined Foreign Offshore Procedures page, including the Form 14653 certification of non-willful conduct. Before filing old reports on their own, read our guide to the Streamlined Foreign Offshore Procedures. The order in which you file matters.

What people get wrong about FBAR reporting

• "No tax is due, so no FBAR is due." The two are unrelated. The FBAR comes from the Bank Secrecy Act, not the tax code.
• "My accountant files my return, so the FBAR is done." The FBAR is a separate filing with a separate agency. Check that it was actually submitted and keep the confirmation.
• "The treaty makes me UK-resident, so I'm exempt." Tax treaties do not affect FBAR obligations.
• "Only accounts over $10,000 count." The threshold is aggregate. Once it is crossed, every account is reported.
• "My pension and ISA are tax-free, so they are not reportable." UK tax treatment has no bearing on US reporting. Both usually belong on the FBAR.
• "Missing a year only risks a small fine per account." After Bittner, non-willful penalties are counted per report, but willful penalties can be a percentage of the balance. How a failure is characterized matters more than how many accounts it involved.

A year of FBAR reporting, step by step

1. In January, gather statements for every UK account you or your children held during the previous calendar year, including accounts you closed.
2. Find each account's highest balance in the year and convert it to dollars at the Treasury rate for December 31.
3. Add the maximums together. If the total exceeds $10,000, every account goes on the report.
4. File FinCEN Form 114 through the BSA E-Filing System by April 15, or by October 15 under the automatic extension.
5. Answer Schedule B consistently on your Form 1040, and check whether Form 8938 is also required.
6. Keep the records for five years: the account name, number, institution, type and maximum value, together with the filing confirmation.

Getting FBAR reporting right

Once you have a list of your accounts, the FBAR is a simple form. The judgment lies in knowing which accounts belong on it, how pensions and signature authority are treated, and how to deal with missed years without making things worse.

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. If you want help with FBAR reporting, we identify your reportable accounts, calculate each maximum value, file FinCEN Form 114 alongside your US return and keep the records on file. 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.