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Foreign account reporting

FBAR filing requirements for Americans in the UK: the short version

The quick answer on who files FinCEN Form 114, the aggregate US$10,000 test, which UK accounts count, the 15 April / 15 October dates, FBAR versus Form 8938 in one table, penalties, and the two routes for missed years.

Published 22 April 2026 · Updated 7 November 2026 · 2 min read

Quick answer. A US person (citizen, green card holder or US resident) living in the UK files FinCEN Form 114, the FBAR, if the combined highest balances of all their non-US financial accounts exceeded US$10,000 at any time in the calendar year. It is filed online with FinCEN, not with the tax return, by 15 April with an automatic extension to 15 October.

The test

Aggregate, not per account: three UK accounts each holding £4,000 cross the line together. Highest balance during the year, not the year-end balance. Accounts you can sign on but do not own count too.

UK accounts that count

Current and savings accounts, cash and stocks-and-shares ISAs, investment platform accounts, joint accounts (reported in full), business accounts you can sign on, Premium Bonds and other NS&I products, SIPPs and defined contribution pensions you can direct, and insurance or annuity contracts with a cash value. Defined benefit schemes and the state pension are treated differently; we state the position taken.

Dates

FBAR (FinCEN 114)Form 8938 (FATCA)
Filed withFinCEN, online, separatelyIRS, with Form 1040
Threshold abroad> US$10,000 aggregate at any time> US$200,000 year-end or > US$300,000 any time (single); double if joint
CoversFinancial accountsAccounts plus other specified foreign assets
Due15 April, automatic extension to 15 OctoberWith the return, including extensions
Penalty if missedNon-wilful up to the inflation-adjusted US$10,000 per reportUS$10,000 per form, rising after notice

Many people file both; filing one never satisfies the other. Full detail in the FATCA guide.

Penalties

Non-wilful: up to US$10,000 per report (inflation-adjusted), applied per form rather than per account since Bittner v. United States (2023). Wilful: the greater of US$100,000 (adjusted) or 50% of the balance, with possible prosecution. Reasonable cause can remove a non-wilful penalty.

Missed years

If all income was reported and only the FBARs were missed, the Delinquent FBAR Submission Procedures: file the late reports with an explanation, and the IRS states no penalty is imposed. If returns or income were also missed, the Streamlined Foreign Offshore Procedures. Both require that the IRS has not already contacted you.

Frequently asked questions

Is the threshold per account?

No. Combined highest balances of every non-US account.

Do I file it with my return?

No. Through FinCEN's BSA E-Filing System. Form 8938 goes with the return.

Joint account with my British spouse?

You report the whole account. Your spouse has no US obligation unless they are also a US person.

We prepare FBARs together with the US return so account lists, balances and exchange rates agree. The longer FBAR guide covers valuation and edge cases.

Written by the US UK Expat Tax advisory team. Last reviewed 7 November 2026 · Figures relate to the 2025 (filed 2026) tax year unless stated.

General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.

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