What Is FBAR Reporting For Cryptocurrency Taxes?

What Is FBAR Reporting?

The Report of Foreign Bank and Financial Accounts, or FBAR, is FinCEN Form 114. It tells the government what you hold at financial institutions outside the US, to make tax evasion through foreign accounts harder.

You don't file the FBAR with your tax return. You file it electronically with the Financial Crimes Enforcement Network (FinCEN), part of the Treasury Department, through the BSA E-Filing System.

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Who Has To File An FBAR?

You file an FBAR if you're a US person and your foreign financial accounts together top $10,000 at any time during the calendar year. Say you have $5,000 in a Canadian checking account and $5,001 at a Hong Kong brokerage at the same moment. That's over $10,000 combined, so you file.

"US person" includes:

• US citizens, including those living abroad
• Green card holders
• US residents under the tax residency rules
• Corporations, partnerships, LLCs, trusts and estates formed under US law

Joint accounts count too. The FBAR is due April 15 for the prior calendar year, with an automatic extension to Oct. 15, according to FinCEN. You don't need to request the extension.

The FBAR applies only to US persons. Readers in other countries have their own reporting rules, covered below.

Is FBAR Reporting Required For Cryptocurrency?

Not for a foreign account that holds only crypto. In Notice 2020-2, FinCEN said a foreign account holding only virtual currency isn't reportable on the FBAR, unless it also holds reportable assets. The same notice said FinCEN intends to amend the rules to include virtual currency. As of Nov. 1, 2026, it hasn't proposed or published that change in the Federal Register.

Stablecoins are a gray area. Notice 2020-2 doesn't address them separately, and neither FinCEN nor the IRS has said whether a foreign account holding only stablecoins falls under the virtual currency exemption. If you hold a large stablecoin balance abroad, ask a tax professional. If your foreign exchange account holds dollars, euros or other government currency, even briefly, the account becomes reportable for that year.

Which Exchanges Count As Foreign?

An account is foreign if it's maintained outside the US. Many large companies run separate US entities, so the same brand can be domestic for one customer and foreign for another.

US accounts for US customers:

• Coinbase (US)
• Kraken (most US states, plus UK, EU, Canada and Australia)
• Gemini (US)
• Binance.US (US), a separate company from Binance.com
• Crypto.com (US accounts through its US entity, plus Global)
• OKX US (US), the US arm of OKX
• Robinhood Crypto (US)

Foreign platforms that don't serve US customers:

• OKX's global platform (Global, not the US)
• KuCoin (Global, not the US). KuCoin agreed to exit the US as part of a January 2025 guilty plea.
• Bybit and Bitget (Global, not the US)
• Binance (Global, not the US). Binance paused withdrawals after an Oct. 29, 2026 hack, and our crypto hacks tracker follows the reimbursement.

A US person who opens an account on a non-US platform may be breaking that platform's terms, and has an account maintained abroad for FBAR purposes. For US readers, the US platforms above avoid the question.

How To File An FBAR

You file online through the BSA E-Filing System by April 15, or by Oct. 15 under the automatic extension.

Gather The Required Information

For each foreign account, you need:

• the name on the account and the account number
• the name and address of the financial institution
• the type of account
• the maximum value during the year

The maximum value is the highest balance at any point, not the year-end balance. If you have $12,000 in an account today but it hit $15,000 in June, you report $15,000. Convert foreign currency to dollars using the Treasury's year-end exchange rate.

Fill Out The Online Form

You enter your personal information, then each account. Accounts you own alone go in Part II, and joint accounts go in Part III. Add a separate entry for each foreign institution.

The current form has no category for a crypto exchange. If FinCEN extends the FBAR to virtual currency, expect new account types to appear, so check the form's instructions each year.

Are There Penalties For Not Filing An FBAR?

Yes, and they're steep. FBAR penalties are adjusted for inflation each year under 31 CFR 1010.821.

These are the latest published figures, which apply to penalties assessed on or after Jan. 17, 2025. FinCEN hadn't published a 2026 adjustment as of Nov. 1, 2026.

In Bittner v. United States, the Supreme Court ruled in 2023 that the non-willful penalty applies once per report, not once per account. Willful violations can also bring criminal charges. Because a crypto-only foreign account is exempt today, these penalties apply to crypto holders only when the foreign account also held reportable assets.

What About Form 8938?

Form 8938, the Statement of Specified Foreign Financial Assets, is a separate requirement under FATCA. You file it with your tax return, not with FinCEN, and it has higher thresholds. Filing one doesn't excuse you from the other.

Say you're single, living in the US, and your foreign accounts totaled $80,000 in June but $45,000 on Dec. 31. You're under the year-end test but over the any-time test, so you file Form 8938.

The IRS's Form 8938 guidance doesn't say whether crypto held at a foreign exchange is a specified foreign financial asset. If you're over the threshold, the cautious approach is to include foreign exchange accounts, since the penalty for a missed Form 8938 starts at $10,000. The IRS has a side-by-side comparison of Form 8938 and the FBAR.

Decentralized Exchanges And Self-Custody Wallets

Decentralized exchanges such as Uniswap don't hold your funds, so there's no foreign account to report. The same goes for a hardware or software crypto wallet where you hold the keys, wherever the wallet maker is based.

That doesn't change your income tax. Every sale or swap on a DEX is still taxable and goes on Form 8949, as our crypto tax rates article explains.

What's Coming Next

Two changes could widen crypto reporting:

• FinCEN's planned FBAR amendment: if FinCEN follows through on Notice 2020-2, foreign accounts holding only crypto would become reportable. No proposed rule had been published as of Nov. 1, 2026.
• The Crypto-Asset Reporting Framework (CARF): an OECD standard under which crypto platforms share customer data with tax authorities. The UK and the EU began collecting data on Jan. 1, 2026. An IRS proposal to bring the US in was sent for White House review in November 2025 and hadn't been published as of Nov. 1, 2026.

Outside the US, other countries have their own foreign asset reports. Canadians, for example, file Form T1135 when the total cost of their specified foreign property tops C$100,000 at any time in the year. The Canada Revenue Agency's crypto guide doesn't say how crypto held on a foreign exchange is treated, so Canadians with large balances abroad should ask a tax professional.

What To Watch Out For

• Cash in a crypto account: a single deposit of dollars or euros at a foreign exchange can make the account FBAR-reportable for the whole year.
• The any-time test: the FBAR uses your maximum balance during the year, not the year-end figure.
• Separate forms: the FBAR and Form 8938 have different thresholds and different agencies. You may owe both.
• Platform risk: foreign exchanges that don't serve the US offer US customers no domestic legal protection, as the Binance withdrawal pause shows.
• Rule changes: check FinCEN's FBAR page each filing season for the virtual currency amendment.

FAQ

Do I Report Crypto On The FBAR?

Not if the foreign account holds only crypto, under FinCEN Notice 2020-2. If the foreign account also holds cash or securities, the whole account counts toward the $10,000 threshold.

Is Binance Or KuCoin A Foreign Account?

Yes. Binance.com, KuCoin, Bybit and OKX's global platform are maintained outside the US. A crypto-only balance there isn't FBAR-reportable today, but none of them serve US customers.

Do I Report A Hardware Wallet On The FBAR?

No. A hardware or software wallet where you control the keys isn't an account at a financial institution, so it's not reportable on the FBAR, wherever the wallet maker is based.

When Is The FBAR Due?

April 15 for the prior calendar year, with an automatic extension to Oct. 15. You file it with FinCEN online, not with your tax return.

What's The Penalty For Not Filing An FBAR?

Non-willful violations can cost up to $16,536 per report, and willful violations up to $165,353 or 50% of the balance, whichever is greater, at the latest adjustment, from January 2025. Willful violations can also be criminal.

Do I Need Form 8938 For Crypto?

Possibly, if your foreign assets top the thresholds, starting at $50,000 at year-end for single filers in the US. The IRS hasn't said directly whether foreign exchange crypto counts, so the cautious approach is to include it.