What bank account thresholds trigger FBAR filing for U.S. persons in 2025?
Executive summary
U.S. persons must file an FBAR (FinCEN Form 114) when the aggregate value of all their foreign financial accounts exceeds $10,000 at any time during the calendar year (official FinCEN and IRS guidance and multiple 2025 practitioner guides state the $10,000 aggregated threshold) [1] [2] [3]. The FBAR is filed electronically with FinCEN; the annual due date is April 15 with an automatic extension to October 15 [2] [1].
1. What exactly triggers the FBAR: the $10,000 aggregate rule
Federal guidance and tax-practice guides converge: the filing trigger is not a per-account limit but the combined, maximum aggregate value of all foreign financial accounts exceeding $10,000 at any point in the calendar year. FinCEN’s public guidance states a U.S. person with financial interest in or signature authority over foreign accounts must file if the aggregate value exceeds $10,000 during the year [1]. Practitioner summaries and law-firm guides for 2025 reiterate that same $10,000 aggregated threshold [3] [4].
2. Who counts as a “U.S. person” and which accounts are included
Available sources list a broad set of filers as U.S. persons: citizens, residents, U.S. entities (corporations, partnerships, LLCs), trusts and estates under Treasury rules — all can trigger FBAR duties if they meet the $10,000 aggregate test [2] [5]. Reportable accounts include foreign bank and brokerage accounts and other foreign financial accounts; some account types are excluded (e.g., accounts held at U.S. military banking facilities, certain IRAs and retirement plans) per IRS guidance [2].
3. How to measure the $10,000 — “at any time during the year” and aggregation pitfalls
The operative measurement is the highest aggregate value reached at any time during the calendar year, not only year-end balances. Multiple sources emphasize that temporary balances and multiple smaller accounts can combine to exceed the threshold [4] [6]. Tax advisers warn about common errors: failing to aggregate jointly owned accounts, business accounts, or accounts where you have signature authority — any of which can push the total over $10,000 [6] [7].
4. Where and when to file — FinCEN’s e‑filing and deadlines
FBARs are filed electronically via the BSA E-Filing System with FinCEN (not with the IRS), and FinCEN’s page repeats the $10,000 trigger language and the e‑file requirement [1]. IRS and practitioner materials state the FBAR annual due date is April 15 following the calendar year, with an automatic extension to October 15 (no separate extension request needed) [2] [8].
5. Penalties and compliance context cited by practitioners
Practitioner and consumer-tax sites stress significant penalties for non‑filing or willful violations and note that relief programs exist for delinquent filers; summaries point to both civil and criminal exposures and cite substantial monetary penalties in recent years [4] [7] [5]. Sources also note FBAR’s separate role from FATCA/Form 8938: thresholds and filing locations differ, so meeting one obligation does not automatically satisfy the other [7] [9].
6. Areas of agreement, practical guidance, and limits of available reporting
All provided sources consistently report a $10,000 aggregate threshold and the April/October filing cadence [1] [2] [3]. Practitioner pieces supply examples (e.g., $4,000 + $7,000 = filing required) to illustrate aggregation [4] [10]. Available sources do not mention any 2025 change to the $10,000 threshold or alternative numeric triggers beyond what FinCEN and the IRS describe; they do not discuss hypothetical legislative proposals or rate-indexing of the threshold (not found in current reporting) [1] [2].
7. Practical takeaways and recommended next steps
If you are a U.S. person with any offshore accounts, tally the maximum combined balances during the year (not just year-end) and file FinCEN Form 114 if that aggregate exceeded $10,000 [1] [6]. File electronically through the BSA E‑Filing System by April 15 (automatic extension to Oct. 15) and keep records; if you missed past filings, practitioner guides point to established delinquent filing procedures that advisers use to seek relief [2] [5].
Limitations: this briefing relies exclusively on the provided IRS/FinCEN pages and 2025 practitioner guides; it does not cover any legislative changes or agency guidance issued after the cited materials and does not substitute for personalized tax or legal advice [2] [1].