FBAR vs FATCA: Reporting requirements for US expats

This publication is provided for general information purposes and does not constitute legal, tax or other professional advice from Wise US Inc. or its affiliates, and it is not intended as a substitute for obtaining business advice from a Certified Public Accountant (CPA) or tax lawyer.

If you have bank accounts in countries other than the US, you might be wondering about your reporting and tax obligations. Two major components of these obligations are the Report of Foreign Bank and Financial Accounts, or FBAR, and compliance with the Foreign Account Tax Compliance Act (FATCA).

The penalties for noncompliance with these laws are strict. Read on for FBAR and FATCA filing requirements, due dates, and more critical information.

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Table of contents
What are FBAR and FATCA? What is the difference between FBAR vs. FATCA? FATCA filing requirements FBAR filing requirements Do I need to file both FBAR and FATCA? Filing requirements for joint foreign financial accounts

What are FBAR and FATCA?

Whether you’re a US taxpayer who lives abroad and banks locally, or you live in the US but own foreign bank accounts, you might need to report these foreign assets via FBAR or FATCA.

FBAR is an annual report called Form 114 that you submit to the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). This form provides information about the foreign bank accounts you own.

Meanwhile, FATCA is part of your personal income tax return that reports the value of your foreign assets. While they sound similar, FBAR and FATCA filing requirements are dramatically different.

Another important difference between FBAR and FATCA lies in their relationship to taxes. To comply with FATCA, you file Form 8938 to the IRS as part of your personal income taxes. FBAR, meanwhile, reports your foreign assets to the US Department of the Treasury through a separate filing process from your tax returns.

What is the difference between FBAR vs. FATCA?

Here's a quick overview of the key differences between FBAR and FATCA. We'll dive into the details below.

	FATCA¹	FBAR²
Who must file	Anyone living abroad with over 200,000 USD in total foreign financial assets by the end of the tax year or 300,000 USD at any time in the course of the year Anyone living in the US with over 50,000 USD in total foreign financial assets by the end of the tax year or 75,000 USD at any time in the course of the year Thresholds double for married couples filing jointly	Anyone with more than 10,000 USD in foreign bank accounts in a given calendar year
What is reported	Specified foreign financial assets	Bank and account information and maximum balances
Where to file	IRS	FinCEN
Filing deadline	The due date of your income tax return	April 15 for the previous calendar year
Penalties	10,000 USD for failure to file Additional 50,000 USD for failure to file after IRS notification, plus a 40% penalty on any tax you underreport from undisclosed assets	No more than 10,000 USD, and the IRS can waive the penalty if you provide sufficient account of your ignorance Willful non-reporting carries a penalty of 100,000 USD or 50% of the balance of your foreign accounts at the time of your violation — whichever is greater

FATCA filing requirements

It’s very important to file for FATCA if you’re required to do so. The penalties are severe. Below, you can see if you meet the threshold for FATCA filing requirements.

Who needs to file for FATCA?

All US taxpayers who meet a significant threshold of foreign assets need to file for FATCA.

For example, let’s say you put substantial amounts of money into a foreign bank account in order to purchase property abroad. This level of investment is often sufficient to trigger FATCA filing requirements.

Your specific threshold for filing FATCA depends on whether you live abroad or in the US and whether you’re married. The FATCA form is called Form 8938.

What are the FATCA filing thresholds?

The filing thresholds for FATCA vary depending on whether you live abroad or in the US, and whether you are married and filing a joint tax return.

For US taxpayers living abroad and filing single, you must file FATCA if you have foreign financial assets totaling over:

• 200,000 USD by the end of the tax year, or
• 300,000 USD at any time in the course of the year

For married couples filing jointly, these thresholds double. Only one spouse in the married couple needs to live outside the US for these thresholds to apply.

In the eyes of the IRS, you “live abroad” if you pay taxes outside of the US and live outside of the US for 330 days out of a consecutive 12-month period (not necessarily a calendar year).¹

For US taxpayers living in the US, you must file FATCA if you have foreign financial assets totaling over:

• 50,000 USD by the end of the tax year, or
• 75,000 USD at any time in the course of the year

For married couples filing jointly, these thresholds double.

If you meet either of these thresholds, you need to submit Form 8938.¹

What are my foreign financial assets?

The IRS uses the term “specified foreign financial assets” with regard to FATCA reporting threshold. This term essentially refers to the collective value of your foreign financial wealth, including bank accounts, but also stocks, securities, and interests in foreign companies.

Some foreign assets are exempt from this reporting threshold. It’s wise to consult with a financial professional to evaluate your foreign assets if you think you’re close to the FATCA requirement.

Keep in mind that the IRS also regulates international wire transfers over 10,000 USD.

Where and when is FATCA filed?

You meet your FATCA filing requirements by filing Form 8938. Your filing deadline for FATCA is the same as your income tax deadline — for most, April 15th — and the form is a part of your individual income tax return.

That being said, filing for FATCA is not the same as reporting your foreign income. Read our guide on how to report US taxes on foreign income to learn more.

FBAR filing requirements

The FBAR filing thresholds are much lower than FATCA. So it’s important to know them well if you have any foreign bank accounts. We’ll get into the details right here.

Who needs to file an FBAR?

If you have a bank account in a foreign country that held any amount over 10,000 USD in a given calendar year, then you need to file an FBAR report to FinCEN for that year.³ This includes multiple bank accounts whose values add up to 10,000 USD.

What is the FBAR filing threshold?

In one number, the filing threshold for FBAR is 10,000 USD. This threshold refers to the total aggregate value of the foreign bank accounts that you owned in a given calendar year.

It doesn’t matter if you have 1,000 USD in one account and 9,001 USD in another; if they add up to more than 10,000, you have to report your accounts.

Where and when is FBAR filed?

You’re required to file FBAR online using FinCEN’s e-filing system unless you request an exemption. FinCEN is part of the US Department of the Treasury.

The due date for FBAR reporting is April 15th. If you miss the deadline, you’ll automatically be extended to October 15th — no extension request necessary. But watch out for penalties after that.

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Do I need to file both FBAR and FATCA?

You need to do your due diligence to meet the requirements for both FBAR and FATCA, as they serve separate purposes and neither of them substitutes for the other.

If your foreign financial assets are substantial enough to meet FATCA filing requirements, and more than 10,000 USD of those assets are in foreign bank accounts, you will need to report those foreign bank assets via FBAR.

There are plenty of instances when taxpayers will have foreign bank accounts that exceed the 10,000 USD FBAR threshold but aren’t high enough to meet the FATCA reporting requirements.

Even though both are usually due on April 15th, FBAR has nothing to do with income tax. FBAR is filed through a separate e-filing system with FinCEN, while FATCA gets filed with your personal income tax return.

💡 Read our complete tax guide for US citizens living abroad for more on FBAR vs. FATCA and other global tax considerations.

Filing requirements for joint foreign financial accounts

FBAR and FATCA filing requirements change when the foreign assets under consideration are jointly owned.

Joint accounts and FBAR:

If you have one or more joint foreign bank accounts that exceed the 10,000 USD threshold, both of you need to file an FBAR. You can both report the full amount or each report your own interest.

If you jointly own your foreign assets with your spouse, then you can either file a consolidated FBAR with both of your assets, or one of you can file a form that authorizes your spouse to file on your behalf.³

Joint accounts and FATCA:

If you are married and file your taxes jointly with your spouse, then your FATCA filing thresholds are double what they would be if you each filed singly. If you do choose to file Form 8938 separately, then each of you needs to report the full value of your jointly owned FATCA-qualified foreign assets.

It's best to consult with a tax professional for specific guidance on joint accounts.

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It can be confusing to untangle FBAR vs. FATCA, but it’s essential to comply with these laws to avoid harsh penalties. Remember that FBAR applies to foreign bank accounts exceeding 10,000 USD, while FATCA has higher thresholds.

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Sources

1. IRS - Summary of FATCA reporting for US taxpayers
2. FinCEN - BSA Requirements for FBAR
3. IRS - FBAR

Sources checked 10/23/2025