FBAR & FATCA thresholds: what counts and when.
Two separate disclosure regimes, two different thresholds, one common outcome: ordinary UK accounts crossing lines their owners never knew existed.
Figures on this page are stated for tax year 2025/26 UK · 2025 US. Thresholds change annually.
$10,000, aggregate, at the year's peak
The FBAR threshold is not per account and not a year-end balance. Add the highest balance each account touched at any point in the year — current accounts, savings, ISAs, many pensions, and accounts you can merely sign on. If the total passes $10,000, every account gets reported.
Moving £8,000 between two accounts can put £16,000 through the test. That is how a modest London salary crosses the line by February.
- All non-US financial accounts count, including ISAs
- Joint accounts and signature authority included
- Measured at each account's annual maximum, then summed
- List every non-US accountCurrent accounts, savings, ISAs, most pensions, joint accounts, and any account you can sign on without owning. Dormant ones count. The list is the part people get wrong, not the form.
- Find each account's highest balance in the yearNot the closing balance and not an average — the single highest point the account reached at any moment during the calendar year. Statements, not memory.
- Convert each peak to US dollarsUse the Treasury year-end rate for the year in question, not the rate on the day the balance peaked. The same rate applies to every account.
- Add the converted peaks togetherSum every account, including the small ones. Money moved between your own accounts counts in both, which is how modest balances cross $10,000 without anyone noticing.
- Compare the total to $10,000Over it, every account on the list is reportable — not just the ones that individually exceeded it. Under it, no FBAR is due for that year, but the test runs again next year.
Form 8938 stacks on top, not instead
FATCA's Form 8938 files with your return and starts at $200,000 for expats filing single ($400,000 joint) at year end — $300,000 and $600,000 if breached mid-year. It covers assets the FBAR misses, and filing one never excuses the other.
Missed years are fixable: the delinquent-FBAR procedures and the Streamlined programme both exist for exactly this, and both must be used before the IRS writes first. Penalties go entirely if you live abroad and qualify for the Foreign route; the Domestic route, for people living in the US, charges 5% of the highest aggregate value instead.
- Expat 8938 thresholds: $200,000/$400,000 year-end
- Penalties start at $10,000 per form for silence
- Delinquent procedures fix missed years without penalties where no income was unreported
| FBAR (FinCEN 114) | Form 8938 (FATCA) | |
|---|---|---|
| Filed with | FinCEN, separately | The IRS, with your return |
| Threshold | $10,000 aggregate, at each account's yearly peak | $200,000 single / $400,000 joint at year end |
| Covers | Financial accounts | Accounts plus other specified assets |
| Penalty from | $16,536 per report, non-willful | $10,000 per form |
Last reviewed · Figures stated for tax year 2025/26 UK · 2025 US. Thresholds and rates change annually — check figures against the current tax year before relying on them.
Not sure if you crossed a threshold?
Send us a rough account list and we will tell you what is reportable — and how to fix any missed years cleanly.