What is the FBAR filing threshold?

You must file an FBAR (FinCEN Form 114) if the aggregate value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year. It's the combined peak, not the year-end balance — if your accounts touched $10,001 for a single day, the obligation is triggered.

What is the difference between FBAR and FATCA Form 8938?

The FBAR is filed with FinCEN (Treasury) and covers foreign financial accounts over $10,000 aggregate. FATCA Form 8938 is filed with the IRS as part of your tax return, covers a broader set of specified foreign financial assets, and has higher thresholds that vary by filing status and whether you live in the US or abroad. Many people must file both.

When is the FBAR due?

The FBAR is due April 15, with an automatic extension to October 15 — you don't have to request the extension. It's filed electronically through the BSA E-Filing System, separately from your income tax return.

What are the penalties for not filing an FBAR?

Non-willful failures carry a penalty of around $16,000 per violation (inflation-adjusted). Willful failures can reach the greater of roughly $160,000 or 50% of the account balance per year, plus potential criminal exposure. Because penalties can exceed the account itself, catching up through the IRS streamlined procedures is usually far cheaper than waiting to be found.

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International Tax

FBAR vs. FATCA: Who Must Report Foreign Accounts — and the Penalties for Missing

If your foreign accounts crossed $10,000 at any point last year, you owe an FBAR — a separate filing from your tax return, with penalties that can dwarf the account balance.

SMAART Tax Team

February 24, 2026

6 min read

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