Often, yes. For the 2025 calendar year, a US citizen living abroad generally must file an FBAR (FinCEN Form 114) if the combined maximum value of their financial accounts outside the US was more than $10,000 at any time during the year. For someone who banks in Dubai, London or Madrid, that threshold is easy to pass, so many US citizens abroad will need to file.

What the FBAR is

The FBAR, or Report of Foreign Bank and Financial Accounts, is a disclosure form, not a tax return. It does not create tax by itself. It tells the US Treasury which non-US accounts you have and the maximum value each reached in the year.

It applies to "US persons", which includes US citizens wherever they live, green card holders and US tax residents. Living abroad does not remove the obligation, and neither does having no US tax to pay.

What counts towards the $10,000

The test is the total of your foreign accounts combined, using each account's maximum value in the year, not the 31 December balance. If that total exceeded $10,000, you generally report every account, including small ones.

Accounts that are often reportable include:

  • bank current and savings accounts outside the US, including in the UAE or UK
  • securities and brokerage accounts with non-US firms
  • non-US mutual funds and similar pooled funds
  • foreign life insurance or annuity contracts with a cash value

It can also cover accounts where you have signature authority but no ownership, such as a company account you can operate, subject to exceptions. Joint accounts are included.

Foreign pensions are not automatically reportable or automatically excluded. Whether a particular pension or retirement arrangement needs reporting depends on the account and how the arrangement is structured, so this should be checked with a US tax specialist.

Deadlines and how to file

  • The FBAR covers the calendar year and is due on 15 April of the following year.
  • There is an automatic extension to 15 October, without needing to ask. Check the dates each year.
  • It is filed electronically through FinCEN's BSA E-Filing System, separately from your tax return.

Keep records of each account, including its name, number, institution and maximum value, for five years from the due date.

Illustrative example only, not a real client.

Laura is a US citizen living in Abu Dhabi. In 2025 she has a UAE current account that peaks at $8,000 and a UAE savings account that peaks at $5,000, and no other foreign accounts. Neither is over $10,000 on its own, but their combined maximum values are $13,000, so she would need to file an FBAR reporting both accounts by 15 April 2026, or by 15 October 2026 under the automatic extension. If she also held a UK ISA with a non-US provider, it would generally count as a foreign financial account and be included.

FBAR and Form 8938 are different

Many US citizens abroad also need Form 8938 under FATCA. It is filed with the tax return, covers a wider range of foreign assets, and its thresholds depend on where you live and your filing status. For taxpayers living abroad, the IRS gives thresholds of more than $200,000 on the last day of the year or more than $300,000 at any time for single filers and married filing separately, and $400,000 and $600,000 for married couples filing jointly. These should be checked against your exact status each year. Filing Form 8938 does not replace the FBAR, and many people need to file both.

If you have missed FBARs

Penalties for failing to file can be significant, and are higher where the failure is wilful. The IRS has procedures for people who have fallen behind, including streamlined procedures for taxpayers whose failure was non-wilful. Which route fits depends on your circumstances, and specialist US tax help is usually worth getting before filing anything late. Our guide to US citizens abroad and their tax obligations covers the wider picture, and see our guide to US estate tax for British expats.

Common mistakes

  • Checking only year-end balances instead of maximum values.
  • Leaving out accounts you can sign on but do not own.
  • Assuming the FBAR is part of the tax return, or that Form 8938 covers it.
  • Thinking no filing is needed because no US tax is due.

A regulated financial adviser can help. Get in touch for a free introduction.

Sources and further reading

Last reviewed: October 2026. Tax year: 2026/27 (UK); 2025 and 2026 calendar years (US). Jurisdictions covered: US, UAE, UK. Rates, legislation and guidance change, so recheck before relying on this. Rules can differ between England and Wales, Scotland and Northern Ireland; tax residence is fact-specific; treaty outcomes depend on residence, domicile or nationality provisions; examples are simplified and omit reliefs, costs, exchange rates and anti-avoidance rules. This is general information, not financial, tax or legal advice. Take advice in the relevant country before acting.