Who must file an FBAR?

Last reviewed: 2026 · Reading time: ~9 minutes

You must file an FBAR for a calendar year if you are a U.S. person who had a financial interest in or signature authority over at least one financial account located outside the United States, and the aggregate value of all such accounts exceeded $10,000 at any time during that year.

1. Are you a “U.S. person”?

For FBAR purposes, a U.S. person includes:

• U.S. citizens — including those living abroad, and dual citizens.
• U.S. residents — generally anyone who meets the “resident alien” tests for tax purposes, such as green-card holders and those who meet the substantial-presence test.
• U.S. entities — corporations, partnerships, and limited liability companies (LLCs) created or organized in the United States.
• Trusts and estates formed under U.S. law.

2. Financial interest vs. signature authority

The requirement covers two distinct types of relationships to an account:

Financial interest

You have a financial interest if you are the owner of record or hold legal title to the account — or if the account is held by someone acting on your behalf, or by an entity you substantially own or control. You can have a financial interest even if you never personally deposit or withdraw money.

Signature authority

You have signature authority if you can control the disposition of assets in the account by delivering instructions (alone or with others) directly to the institution. This is common for people who manage a foreign account for an employer, a family member, or an organization — even when they own none of the money.

3. The $10,000 aggregate threshold

This is the step most often misunderstood. The $10,000 test is aggregate, meaning you add up the highest balance of every foreign account and compare the total — not each account individually — to $10,000.

The threshold is measured using the maximum value each account reached at any point during the calendar year, not the year-end balance.

Which accounts are reportable?

Generally reportable foreign accounts include:

• Bank accounts — checking, savings, and time/fixed deposits
• Securities, brokerage, and investment accounts
• Certain foreign mutual funds and pooled investment funds
• Foreign pension or retirement accounts (treatment varies — verify)
• Insurance or annuity policies with a cash value
• Accounts held at a foreign branch of a U.S. financial institution

Which accounts are generally NOT reportable?

• Accounts held at a U.S. branch of a foreign bank (these are domestic)
• Certain accounts owned by a governmental entity or international financial institution
• Accounts held in an individual retirement account (IRA) or certain U.S. retirement plans
• Physical assets held directly (e.g., cash in a safe, gold bars stored yourself) — an account is required, not just an asset

Special situations

Joint accounts & spouses

Each U.S. person with a financial interest in a joint account generally must report it. In some cases a spouse can be included on the other spouse's FBAR, but only if specific conditions are met and the proper authorization is filed. Otherwise, each spouse files their own.

Children

There is no age exemption. A child who is a U.S. person and meets the threshold has an FBAR requirement; a parent or guardian can file on the child's behalf.

Business owners

Owning more than 50% of an entity that holds a foreign account can give you a reportable financial interest in that account, in addition to any filing the entity itself must make.

Quick summary

Ask yourself: (1) Am I a U.S. person? (2) Did I have a financial interest in or signature authority over a foreign account? (3) Did my foreign accounts together exceed $10,000 at any point last year? If the answer to all three is yes, you very likely have an FBAR to file.

This article is general educational information and is not legal, tax, or financial advice. Individual circumstances vary and exceptions apply. Verify details with official government sources and a qualified professional. See our full disclaimer.