FBAR and FATCA: Reporting UK Bank Accounts as a US Citizen

What are FBAR and FATCA — and why do they exist?

When Americans move to the UK, they naturally open bank accounts, build savings, and invest through British financial institutions. From HMRC's perspective, this is entirely unremarkable — money in a British account is simply a British financial life. From the IRS's perspective, however, it raises a question: where is all this money, and how much of it is there?

FBAR and FATCA are the two systems through which the U.S. government gets its answer. Both require Americans abroad to disclose foreign financial accounts and assets to U.S. authorities. Neither is a tax — filing them does not, by itself, create any extra tax liability. They are transparency requirements, born from the U.S. government's concern that offshore accounts could be used to conceal income or assets from the IRS.

Understanding them matters because the penalties for ignoring them are serious, and because many Americans in the UK trigger the filing thresholds through entirely routine banking — a current account, a savings account, a joint account with a partner — without ever realising it.

FBAR: Reporting foreign bank accounts

What is FBAR?

FBAR stands for Report of Foreign Bank and Financial Accounts. The formal name of the filing is FinCEN Form 114 — it goes to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury, not to the IRS directly. It was created under the Bank Secrecy Act of 1970, which is why it operates entirely separately from your tax return.

The FBAR is not filed with your Form 1040. It is submitted electronically through FinCEN's BSA E-Filing System at bsaefiling.fincen.gov. This trips up many first-time filers who assume everything goes through the IRS.

Who must file an FBAR?

You must file an FBAR if all three of the following apply:

• You are a U.S. person — this means U.S. citizens, green card holders, and resident aliens. It also includes certain U.S.-based trusts, estates, corporations and partnerships.
• You have a financial interest in, or signature authority over, at least one financial account located outside the United States.
• The aggregate value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year.

What counts as a foreign financial account?

The definition is broader than most people expect. For Americans in the UK, it includes:

• UK current accounts (everyday banking)
• UK savings accounts, including ISAs
• Joint accounts with a British spouse or partner
• UK investment accounts and brokerage accounts
• UK pension accounts (workplace pensions, SIPPs)
• Accounts at UK building societies
• Foreign mutual funds held in accounts outside the U.S.
• Accounts in which you have only signature authority — for example, a company account you can sign on, or an elderly parent's account where you hold power of attorney

What does not count: real property held directly (not through an account or entity), accounts at U.S. military banking facilities, and IRAs or U.S. pension plans investing in foreign securities through U.S. institutions.

What information do you need to file?

For each account that must be reported, you will need:

• The name on the account
• Account number (or other identifying information)
• Name and address of the financial institution
• Type of account (bank, securities, other)
• The maximum value the account reached during the year, converted to U.S. dollars

For currency conversion, FinCEN instructs filers to use the Treasury's year-end exchange rate. Keep your bank statements and note the highest balances — if you track this through the year, filing becomes a 20-minute exercise rather than a document-hunting exercise in April.

FBAR deadline 2026

The FBAR for the 2025 tax year is due April 15, 2026. There is an automatic extension to October 15, 2026 — no form or request is needed to use it. This is separate from any extension you request for your tax return; they do not affect each other.

FATCA and Form 8938: Reporting foreign financial assets

What is FATCA?

FATCA stands for the Foreign Account Tax Compliance Act, passed into law in 2010. Where FBAR asks about foreign accounts, FATCA asks about a broader range of foreign financial assets. You comply with FATCA as an individual by filing Form 8938 (Statement of Specified Foreign Financial Assets) — attached to your annual tax return, not filed separately.

Unlike FBAR, Form 8938 goes to the IRS as part of your Form 1040. If you are not required to file a U.S. income tax return, you are not required to file Form 8938 even if you hold significant foreign assets.

Who must file Form 8938?

You must file Form 8938 if you are required to file a U.S. income tax return and your specified foreign financial assets exceed the thresholds below. Because you are living in the UK, the thresholds that apply to you are the higher abroad rates:

These thresholds are significantly higher than the FBAR threshold, which is why many Americans in the UK must file an FBAR but not Form 8938. If your total foreign financial assets stay well below $200,000, FATCA reporting is unlikely to apply to you — but the FBAR obligation at $10,000 almost certainly does.

What counts as a specified foreign financial asset?

Form 8938 covers a broader range than FBAR. As well as foreign bank and financial accounts, it includes:

• Stocks or securities issued by foreign companies
• Interests in foreign partnerships
• Foreign-issued life insurance policies with a cash value
• Foreign annuity contracts
• Interests in foreign trusts or foreign estates
• Certain foreign pension plans

Notably, foreign real estate held directly — a house you own in the UK in your own name — does not need to be reported on Form 8938. However, if you hold it through a foreign entity such as a company, your interest in that entity may be reportable.

FBAR vs Form 8938: Key differences

The two requirements overlap but are not identical. Filing one does not satisfy the other. Here is a direct comparison:

Penalties for non-compliance

The penalty structure for FBAR and FATCA is worth understanding clearly — not to create alarm, but because the numbers are large enough that they change behaviour. The key distinction in every case is between non-willful violations (honest mistakes, lack of awareness, or incorrect advice) and willful violations (deliberate concealment).

For Form 8938 (FATCA), the initial penalty for failure to file is $10,000, with an additional $10,000 for each 30-day period of continued non-compliance after IRS notice, up to a maximum of $50,000. There is also a 40% accuracy-related penalty on any tax understatement linked to unreported foreign assets.

Most Americans who find themselves non-compliant are in the non-willful category — they simply did not know about the requirement, or misunderstood how the threshold worked. The IRS has clear processes for coming into compliance without facing maximum penalties.

What to do if you've never filed

This is more common than the official tone of tax compliance literature suggests. Many Americans arrive in the UK, open bank accounts, build a life, and spend years not knowing that FBAR exists. When they find out, the instinct is often to stay quiet and hope the problem goes away. It does not — but the process for catching up is more manageable than many people fear.

Delinquent FBAR Submission Procedures

If you have never filed FBAR and your tax returns are otherwise up to date, you can use the Delinquent FBAR Submission Procedures. Under these, the IRS generally will not impose penalties if you were properly reporting your foreign income, the IRS has not already contacted you about a compliance issue, and your failure to file was non-willful. You file the missing FBARs electronically and include a brief statement explaining why they were not filed on time.

Streamlined Filing Compliance Procedures

If both your FBARs and your tax returns are overdue, the Streamlined Filing Compliance Procedures provide a structured path to compliance. For expats, the offshore version (Streamlined Foreign Offshore Procedures) generally requires filing three years of amended or delinquent returns and six years of FBARs. If you meet the non-willful criteria, penalties are typically zero or minimal.

How to file: step-by-step

• 1
  Identify all foreign financial accounts

  List every account you hold outside the U.S.: current accounts, savings accounts, ISAs, workplace pension, SIPP, investment accounts, joint accounts. Include any accounts where you have only signature authority.

• 2
  Find the maximum balance for each account

  Look at your bank statements and note the highest balance each account reached at any point during the calendar year — not just the year-end figure.

• 3
  Convert to U.S. dollars

  Use the U.S. Treasury's year-end exchange rate (published at fiscaldata.treasury.gov) to convert pound balances to dollars. Apply one consistent method.

• 4
  Check the threshold

  Add up the maximum values across all accounts. If the total at any point during the year exceeded $10,000, you must file FBAR for that year.

• 5
  File through the BSA E-Filing System

  Go to bsaefiling.fincen.gov. Select FinCEN Form 114. Enter your personal details and the details of each account. Sign electronically and submit. Save your BSA confirmation number.

• 6
  Keep records for five years

  FinCEN requires you to keep records supporting your FBAR — account statements, maximum balance notes, exchange rate documentation — for five years from the filing date.

Common UK scenarios

Scenario 1: Standard employed expat

You moved to London for work. You have a Barclays current account (max balance £8,500), a Marcus savings account (max balance £6,000), and a Monzo account (max balance £1,200). Combined: £15,700 — well over the $10,000 threshold at sterling-dollar exchange rates. FBAR is required. Form 8938 is unlikely to be required unless you have significant investments.

Scenario 2: Joint account with British spouse

You have a joint account with your British spouse. The account's maximum balance during the year was £22,000. You report the full value of the joint account on your FBAR. Your spouse, not being a U.S. person, has no FBAR obligation. If you and your spouse want to file a single FBAR covering only jointly-held accounts, both must sign FinCEN Form 114a authorising the joint filing.

Scenario 3: Signature authority over a company account

You are a director of a UK company and can sign on the company's Lloyds business account. Even if you have no ownership interest in the funds, signature authority alone triggers an FBAR obligation for that account if it contributes to crossing the $10,000 threshold.

Scenario 4: Workplace pension

Your UK employer contributes to a workplace pension on your behalf. The pension account is a foreign financial account for FBAR purposes. The pension's value counts toward the aggregate threshold. For Form 8938, UK pension treatment is more complex and may warrant professional guidance — particularly for defined benefit schemes and SIPPs.

FBAR and FATCA compliance can feel daunting, but for most Americans in the UK the obligations are simpler than they first appear. Ordinary banking — a current account, a savings account, possibly an ISA — will almost always cross the $10,000 FBAR threshold. Filing takes minutes once you have your account details to hand, and the automatic extension to October gives you time to gather them properly.

Where it gets genuinely complex is pensions, ISAs held as investments, property owned through entities, or years where you didn't file at all. Those situations warrant professional advice — not because the rules are unknowable, but because the cost of getting them wrong is disproportionately high relative to the cost of getting specialist help.

If you take one thing from this guide: file every year, file on time, and if you've missed years, address it proactively — the amnesty procedures exist precisely for that.

Disclaimer: This guide is for general information only and does not constitute tax, legal or financial advice. FBAR and FATCA rules are complex and individual circumstances vary — always consult a qualified tax professional before making filing decisions. Penalties and thresholds are correct as of March 2026 but may be adjusted for inflation annually. Verify all details with the IRS, FinCEN, or a licensed adviser.