If you are a US citizen who opens bank accounts in the countries you work from, FBAR for digital nomads is the filing most likely to catch you off guard. Skipping it can cost far more than skipping your tax return, even when you owe no tax at all. This guide explains who has to file, what counts as a foreign account (including Wise, Revolut and crypto exchanges), how Form 8938 differs, what the penalties look like, and what to do if you are behind.
Last checked against official sources in October 2026.
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What Is the FBAR and Why Does It Matter for Nomads?
The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. It is not a tax form and it is not filed with your tax return. It is filed with the Treasury’s Financial Crimes Enforcement Network (FinCEN) through the BSA E-Filing System. The IRS enforces it.
In plain terms, FBAR for digital nomads works like this. Per the IRS FBAR page, a US person must file if they have a financial interest in, or signature or other authority over, at least one foreign financial account, and the combined value of all such accounts exceeded $10,000 at any time during the calendar year. US persons include citizens, residents, and entities such as LLCs and corporations.
That is why the FBAR is a common problem for nomads. A nomad might hold a Thai bank account, a Portuguese account, a Wise balance and a Revolut balance. None of them may feel large, but the $10,000 test is an aggregate of the highest balance in each account. Add them up and you can cross the line without ever feeling wealthy.
FBAR for digital nomads is a separate duty from your income tax filing. Claiming the exclusion described in our foreign earned income exclusion guide does nothing to remove it.
FBAR for Digital Nomads: Who Must File
Under the FBAR for digital nomads rules, you must file if all three of these are true:
- You are a US person (citizen, green card holder, or US resident for tax purposes).
- You have a financial interest in, or signature or other authority over, a foreign financial account.
- The aggregate maximum value of all your foreign accounts exceeded $10,000 at any time in the calendar year.
The threshold is $10,000 total, not per account. Use the highest balance each account reached during the year, convert to US dollars, and add them together.
Two exceptions from the IRS page are worth knowing. You do not need to file if all of your foreign accounts are included on a consolidated FBAR. You also do not need to file if you jointly own all of them with your spouse and your spouse files a timely FBAR covering them after you sign FinCEN Form 114a.
FBAR for Digital Nomads: Deadline and Automatic Extension
The FBAR for digital nomads is due April 15 following the calendar year being reported. If you miss April 15, an automatic extension to October 15 applies, and you do not need to ask for it. For tax year 2025, that meant April 15, 2026, with the extension running to October 15, 2026.
The calendar for FBAR for digital nomads differs from your Form 1040. Americans living abroad get an automatic extension for the return, but the FBAR has its own calendar and its own system, so do not assume one date covers both.
Keep records for five years from the due date. Good record keeping makes FBAR for digital nomads far easier. The IRS lists what to keep: account name and number, the foreign bank’s name and address, the account type, and the maximum value during the year.
What Counts as a Reportable Account for FBAR for Digital Nomads
For FBAR for digital nomads, the test is generally any account at a financial institution outside the United States, whether or not it earns taxable income. Here is how it plays out for the accounts nomads actually use.
Bank accounts and signature authority
Local checking and savings accounts abroad count. So do accounts where you can sign or direct the money but do not own it, such as a business account you manage or a family member’s account on which you are a signer. The FBAR covers signature authority; Form 8938 generally does not.
Wise, Revolut and other fintechs
What matters is the legal entity that holds your money, not the currency or the routing number. According to Taxes for Expats, Wise US Inc. is US-based, while Wise Europe SA (Belgium), Wise Payments Ltd (UK) and Wise Australia Pty Ltd are foreign. For Revolut, Revolut Ltd (UK) and Revolut Bank UAB (Lithuania) are foreign, while Revolut Technologies Inc. is US-based. Check the entity named in your account agreement, and compare options in our Wise vs Revolut vs Payoneer vs Schwab guide.
Crypto exchanges
Here the rule is unsettled. FinCEN Notice 2020-2 says the current FBAR regulations do not treat a foreign account holding only virtual currency as a reportable account, but FinCEN stated it intends to propose a rule that would change that. The notice also means an account that holds other assets, such as cash or securities alongside crypto, can still be reportable. Many preparers handling FBAR for digital nomads treat an active foreign exchange account as reportable to be safe. Confirm the current status with a professional before you file.
Foreign pensions
Foreign pension and retirement plans are generally treated as reportable, even if you have not contributed or taken distributions since becoming a US person, according to Golding & Golding. The IRS exclusion for retirement plans applies to US IRAs and retirement plans, so do not assume a foreign scheme is exempt.
Joint accounts
Joint accounts are reportable for FBAR for digital nomads. If you and a partner both have access to a local account, each person with a financial interest or signature authority may need to report it, subject to the spouse exception above.
Form 8938 and FATCA: How They Differ From FBAR for Digital Nomads
FATCA, the Foreign Account Tax Compliance Act, works from two sides. Foreign banks and other foreign financial institutions must identify and report accounts held by US persons, or face withholding on certain US-source payments, according to the IRS FATCA page. In return, individuals report their own specified foreign financial assets on Form 8938, which is attached to the income tax return.
So your bank abroad may already be telling the IRS that you hold an account with them. If you skip your own reporting, the numbers will not match.
Form 8938 thresholds
Per the IRS FATCA summary, you are treated as living abroad if you are a US citizen whose tax home is in a foreign country and you were present abroad at least 330 days in a consecutive 12-month period. Those thresholds are much higher than for people living in the US.
| Filing status | Living in the US: year-end / any time | Living abroad: year-end / any time |
|---|---|---|
| Single | $50,000 / $75,000 | $200,000 / $300,000 |
| Married filing jointly | $100,000 / $150,000 | $400,000 / $600,000 |
| Married filing separately | $50,000 / $75,000 | $200,000 / $300,000 |
FBAR vs Form 8938 side by side
| FBAR (FinCEN Form 114) | Form 8938 | |
|---|---|---|
| Filed with | FinCEN, electronically | IRS, attached to your income tax return |
| Threshold | More than $10,000 total at any time in the year | $200,000 year-end or $300,000 any time (single, abroad) |
| Same threshold for nomads abroad? | Yes, no higher limit abroad | No, higher limits if you qualify as living abroad |
| Signature authority accounts | Included | Generally not |
| Due | April 15, automatic extension to October 15 | With your tax return, including its extensions |
| Who it is for | Anyone with qualifying foreign accounts | Individuals who must file an income tax return and exceed the thresholds |
For most people, FBAR for digital nomads applies even when Form 8938 does not, because the FBAR threshold is so much lower. Filing one never replaces the other.
FBAR for Digital Nomads: Penalties
The penalty is the reason FBAR for digital nomads deserves attention. The IRS notes that civil maximums are adjusted annually for inflation. Under FinCEN’s inflation adjustment, per 31 CFR 1010.821, penalties assessed on or after January 17, 2025 are:
| Violation | Statutory base | Inflation-adjusted maximum |
|---|---|---|
| Non-willful | $10,000 | $16,536 |
| Willful | $100,000 (or 50% of the account balance, if greater) | $165,353 (or 50% of the balance, if greater) |
Under IRS manual guidance, non-willful penalties across all open years generally cannot exceed 50% of the highest aggregate balance of the accounts involved. Willful violations can also carry criminal penalties. These figures can change with each annual adjustment, so check the current table before relying on them.
Form 8938 has its own penalties, separate from FBAR for digital nomads penalties. The IRS lists a $10,000 failure-to-file penalty, up to an additional $50,000 for continued failure after notice, and a 40% penalty on understatements tied to undisclosed assets. No penalty applies if you show reasonable cause and not willful neglect.
What If You Are Behind on FBAR for Digital Nomads?
First, the big change. In July 2026, the IRS removed the Delinquent FBAR Submission Procedures from its website, according to Kaufman Rossin. That route used to let people with no unreported income file late FBARs without a penalty. The underlying law did not change, but the published path is gone, so late filers now rely on reasonable cause explanations or the other IRS programs.
The Streamlined Foreign Offshore Procedures are still on the IRS website. They are designed for people whose failures were non-willful and who live abroad.
- Eligibility: US citizens must show that, in at least one of the three most recent years with a passed due date, they had no US abode and were outside the US for at least 330 full days.
- What to file: Returns for the three most recent years, plus required information returns, and delinquent FBARs for the six most recent years.
- Penalty: If you qualify and follow the instructions, the IRS says you are not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. You still owe any tax and interest.
- Certification: Form 14653 certifying that the conduct was non-willful.
- Not available if: the IRS has started a civil examination of your returns or you are under criminal investigation.
If there is any chance your conduct could be called willful, talk to a tax attorney before filing anything. Our guide to the best expat tax preparers covers providers who handle catch-up filings, though complex cases belong with an attorney.
A Simple Annual Routine for FBAR for Digital Nomads
- Start the FBAR for digital nomads checklist by listing every account you hold or can sign on.
- Record the highest balance in each account during the calendar year, in the original currency.
- Convert to dollars with the Treasury’s year-end exchange rate and add it up.
- If the total is above $10,000, file FinCEN Form 114 by April 15 (October 15 with the automatic extension).
- Test Form 8938 separately against the higher abroad thresholds.
- Keep records for five years, so next year’s FBAR for digital nomads filing starts from a clean list.
Choosing where to bank also changes your exposure to FBAR for digital nomads. Our offshore banking for digital nomads guide covers the trade-offs, and our best bank accounts for digital nomads comparison shows which accounts are easiest to run from abroad. For the wider US picture, see digital nomad taxes for Americans. For anything complicated in FBAR for digital nomads, work with an enrolled agent, CPA or tax attorney.
Frequently Asked Questions
Does FBAR for digital nomads apply if I owe no US tax?
Yes. FBAR for digital nomads is not a tax calculation. If your foreign accounts together exceeded $10,000 at any time in the year, you must file regardless of how much tax you owe.
Is the FBAR threshold higher if I live abroad?
No. The $10,000 aggregate threshold is the same for everyone. Only Form 8938 has higher thresholds for taxpayers who qualify as living abroad.
Do Wise and Revolut accounts count for FBAR?
It depends on which legal entity holds your balance. Accounts held by foreign entities, such as the UK or Belgian Wise companies, are generally reportable, while accounts held by US entities generally are not.
Do I have to report crypto held on a foreign exchange?
FinCEN Notice 2020-2 says an account holding only virtual currency is not currently reportable on the FBAR, but FinCEN has said it intends to change the rule. An account that also holds cash or securities can be reportable, so ask a professional.
What happens if I skipped FBAR for digital nomads for several years?
If your failure was non-willful and you live abroad, the Streamlined Foreign Offshore Procedures may let you catch up without penalties. If your situation could be seen as willful, speak to a tax attorney first.
Also read: Offshore Banking for Digital Nomads | Best Expat Tax Preparers | Foreign Earned Income Exclusion 2026 | Digital Nomad Taxes for Americans | Wise vs Revolut vs Payoneer vs Schwab
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