Money and taxes

FBAR for Americans in Italy (2026)

By Steven DavisFacts checked October 24, 2026

Who files

US citizens and residents whose foreign accounts total more than $10,000 at any time in the year

Form

FinCEN Form 114, filed online through the BSA E-Filing System

Deadline

April 15, with an automatic extension to October 15

Exchange rate for 2025 reports

0.851 euros per dollar (Treasury, December 31, 2025)

Non-willful penalty

Up to $16,536 per report (penalties assessed on or after January 17, 2025)

Form 8938 if you live abroad, single

Over $200,000 on December 31 or over $300,000 at any time

Who has to file an FBAR

The FBAR (Report of Foreign Bank and Financial Accounts) is a yearly report under the Bank Secrecy Act. It goes on FinCEN Form 114 to the Financial Crimes Enforcement Network, a Treasury bureau.

You must file if both of these are true:

• You are a US person: a US citizen (minor children included) or US resident, or a US entity.
• You have a financial interest in, or signature authority over, foreign accounts worth more than $10,000 combined at any time in the year.

Moving to Italy changes neither point. The IRS states that tax treaties do not affect FBAR obligations, and an account that earns no income still counts.

The test is the total, not any single account. In an IRS example, a filer with accounts of $3,000, $1,000 and $8,000 must report all three.

What counts as a foreign account in Italy

What matters is where the account is held, not which bank runs it. A US bank's branch abroad is foreign; a foreign bank's US branch is not.

The regulation (31 CFR 1010.350) covers:

• Bank accounts: a conto corrente (checking account), savings, or a conto deposito (term or savings deposit account).
• Accounts with anyone in the business of accepting deposits, which is how the rule reads for a BancoPosta account at Poste Italiane.
• Securities and brokerage accounts, and mutual funds open to the public.
• Insurance or annuity policies with a cash value, such as whole life policies. The IRS comparison chart marks foreign-issued cash-value life insurance and annuities as reportable.

FinCEN and the IRS do not name Italian pension products. IRS Publication 5569 does list foreign retirement accounts, such as Canada's RRSP and Mexico's AFORE accounts, as reportable. Social security-type benefits from a foreign government are not reportable.

Signature authority means you can move the money by instructing the bank. A power of attorney over a parent's account abroad counts if it gives you that power, even if you never use it.

How to work out the maximum value

For each account, take the highest balance during the year in euros. Convert it at the Treasury Reporting Rate of Exchange for December 31, and round up to the next whole dollar.

Treasury's euro rate for December 31, 2025 is 0.851 euros per dollar. Divide euro amounts by 0.851.

This filer reports both accounts, though neither reached $10,000. For 2025, a combined maximum above €8,510 crosses the line. Reports for 2026 use the December 31, 2026 rate.

With fewer than 25 accounts and no way to tell whether you crossed $10,000, you can list each account and check "amount unknown."

When and how to file

1. Gather records for each account: the name on it, the account number, the bank's name and address, the type and the maximum value.
2. File online through FinCEN's BSA E-Filing System. Individuals can use the no-registration option. Paper filing needs an exemption from FinCEN.
3. File by April 15 for the previous calendar year. If you miss it, an automatic extension runs to October 15, with nothing to request.
4. Answer the foreign account questions on Schedule B (Form 1040), questions 7a and 7b, when you file your tax return.
5. Keep records for 5 years from the FBAR due date.

Joint accounts. Each US owner reports the full balance. Spouses who own every foreign account jointly can file one FBAR if both sign Form 114a and keep it.

Using a preparer. A CPA, attorney or enrolled agent files as a registered institution, with your signed Form 114a.

From abroad, FinCEN's Regulatory Helpline is 703-905-3975 and the IRS FBAR Hotline is 313-234-6146.

Penalties after the Bittner decision

Penalty maximums are set in 31 CFR 1010.821 and must be adjusted for inflation each year. The latest adjustment took effect January 17, 2025, and still applied in October 2026. For penalties assessed on or after that date:

On February 28, 2023, the Supreme Court reversed the lower court in Bittner v. United States. The IRS manual now treats a failure to file a correct FBAR as a single violation. A non-willful failure can bring one penalty per report, however many accounts it missed.

The amounts are ceilings, and examiners can issue a warning letter instead. Criminal penalties also exist for willful violations.

How the FBAR fits with Form 8938 and Italy's rules

Form 8938 comes from FATCA (the Foreign Account Tax Compliance Act). It is attached to your tax return, and filing one never replaces the other.

Living abroad means a bona fide resident abroad for the full tax year, or abroad at least 330 days in 12 consecutive months. No tax return due means no Form 8938.

Italian tax residents also report foreign assets to Italy, in the quadro RW (foreign assets section) of the Italian return. See taxes in Italy for Americans.

Why your Italian bank asks if you are American

Under FATCA, foreign banks report on accounts held by US persons. Italy's agreement with the US, signed in Rome on January 10, 2014, was ratified by Law 95 of 2015.

For each account a bank identifies as a US reportable account, Italy sends the US the holder's name, address, US taxpayer number, account number and year-end balance every year. Unless the bank elects otherwise, deposit accounts of $50,000 or less are exempt.

At opening, the bank may require a self-certification with your US taxpayer number, such as an IRS Form W-9. That is why an Italian bank or insurer may ask for your Social Security number. None of this files your FBAR for you.

Common problems and fixes

You missed past years. If the IRS has not contacted you, it says to file the late FBARs as soon as possible. For failures that were not willful, its streamlined foreign offshore procedures take 3 years of returns and 6 years of FBARs. Qualifying filers pay no FBAR penalty.

No single account is over $10,000. Add the maximums: €6,000 and €4,000 put you over for 2025.

A joint account with your Italian spouse. You report the full balance. Your spouse files only if also a US person.

You counted on the June 15 tax extension. The FBAR has its own dates: April 15, then October 15 automatically.

Do you need help with this?

Most people with a few Italian bank accounts can file the FBAR on their own once they have their statements. It gets harder with years of missed filings, insurance or investment products, or accounts you hold through a company or trust.