Who must file — quick refresher
- Who: A U.S. person (citizen/resident; U.S. entities, trusts, estates).
- When: If you have a financial interest in, or signature or other authority over, one or more foreign financial accounts, and the aggregate maximum value exceeded $10,000 at any time during the calendar year.
Deadline: April 15 (automatic extension to October 15). File electronically via FinCEN’s BSA E-Filing System.
Three buckets of reportable accounts
By regulation, FBAR covers bank accounts, securities accounts, and other financial accounts maintained by a financial institution in a foreign country.
1) Bank accounts
- Checking/current, savings, time deposits/CDs, foreign-currency accounts at non-U.S. banks or equivalent institutions.
- Stored-value/e-money accounts at foreign financial institutions may also be in scope.
2) Securities accounts
- Brokerage/custody accounts at foreign brokers or custodians holding stocks, bonds, ETFs, ADRs/GDRs, etc. (the account is reportable; not each security individually).
3) Other financial accounts
- Cash-value life insurance / annuities with surrender value.
- Futures/options/commodities accounts maintained by a foreign FCM/member.
- Mutual funds or similar pooled funds offered to the public, with regular NAV and redeemable shares.
- Certain foreign retirement/pension or superannuation accounts held with a foreign financial institution.
Key principle: FBAR is about the account relationship with a foreign financial institution. Asset type alone does not decide reportability — look at whether a foreign financial account exists and whether you have financial interest or signature authority.
Classifying your relationship: Owned vs. Joint vs. Signature Authority
Owned (financial interest)
- Your name is on the account, or you own it through an entity or trust you control. Generally, if you own >50% of an entity that owns the account, you are treated as having a financial interest.
Joint
- Your name appears as a joint holder; you have a financial interest. Spousal rules may allow combined reporting in some cases.
Signature or other authority (no ownership)
- You can control the disposition of assets by direct communication to the institution, but you are not an owner (e.g., company treasury staff; an adult child with signing authority on a parent’s account, or vice versa).
- Possible exemptions: certain employees of U.S. banks, SEC/CFTC-regulated institutions, registered investment companies, or U.S. listed companies may be exempt from filing for signature-authority-only accounts (subject to conditions).
Parents/children: If you are a named joint holder — report as Joint. If you only have signing authority and are not an owner — report as Signature Authority.
Crypto: do foreign crypto exchange accounts need FBAR?
Current rule (2025): An account that holds only virtual currency is not currently a reportable account for FBAR purposes. If the same account also holds fiat or other reportable assets, the account may be reportable. Regulators have stated intent to propose rules in the future, so re-check guidance each year.
Practical tip: If your foreign exchange wallet also holds fiat balances, evaluate it like any other foreign financial account and include it in your aggregate maximum value if applicable.
Quick classification table (common scenarios)
| Scenario / Account | Reportable foreign financial account? | How to classify | Notes |
|---|---|---|---|
| Foreign bank checking/savings/term deposit | Yes | Owned / Joint / Signature | Classic “bank account.” |
| Foreign brokerage/custody account (stocks/bonds/ETFs) | Yes | Owned / Joint / Signature | Classic “securities account.” |
| Cash-value life insurance or annuity (foreign insurer) | Usually yes | Owned | “Other financial account.” |
| Foreign futures/options/commodities account | Usually yes | Owned / Signature | Maintained by foreign FCM/member. |
| Foreign mutual fund / similar public fund (redeemable shares) | Usually yes | Owned | Regular NAV; redeemable units. |
| Foreign pension/superannuation account | Often yes | Owned | When maintained by a foreign financial institution. |
| Company account (you own >50% of entity) | Yes | Owned (indirect) | Financial interest via entity. |
| Parent/child account — you are joint holder | Yes | Joint | Financial interest. |
| Parent/child account — you have signing authority only | Yes | Signature authority | No ownership, but control over disposition. |
| Foreign exchange account holding only virtual currency | Not currently | — | Status may change; re-check annually. |
| U.S. military banking facility account (overseas) | Generally no (exception) | — | Specific regulatory exceptions apply. |
Examples and edge cases
- Closed during the year? If an account existed at any time during the year and your aggregate exceeded $10,000, include it and mark as closed.
- 25+ accounts? Special summary rules apply for filers with signature authority only or many accounts (see FinCEN e-filing specs).
- Entity vs. individual filing: The entity itself may have an FBAR duty. Tax status (e.g., disregarded entity) does not determine FBAR duty.
Tools: rates & spreadsheet
- Need USD conversions? Use the SafeFBAR Exchange Rate Calculator (Treasury year-end rates).
- Prefer a filing-ready workbook? Download the SafeFBAR Excel template (PQ) — auto FX for 150+ currencies and fields aligned to the online form.
FBAR gets easier once you separate: Is there a foreign financial account? and What is my relationship to it (owned/joint/signature)? Use the table above as a checklist each year.