FBAR Requirements for Crypto Accounts Over $10,000 in 2025
Nov, 7 2025
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Important Notes
Key facts:
- As of 2025, pure crypto accounts (holding only cryptocurrency) are not required to file an FBAR
- Hybrid accounts (holding cryptocurrency AND fiat) do require filing if total value exceeds $10,000
- FBAR filings are due April 15, 2026 (with automatic extension to October 15, 2026)
- Non-willful violations can cost up to $10,000 per violation
- FinCEN is expected to update rules to require FBAR filing for all foreign crypto accounts in the near future
If you hold cryptocurrency on a foreign exchange like Binance, KuCoin, or Bitfinex, and your total balance across all foreign accounts hit $10,000 at any point in 2025, you might be required to file an FBAR. But here’s the twist: FBAR requirements for crypto accounts aren’t as clear-cut as they are for bank accounts. Right now, the rules are in a gray zone-and what you do today could save you from a $10,000 penalty tomorrow.
What Is an FBAR, Really?
FBAR stands for Foreign Bank and Financial Account Report. It’s not a tax form. It’s a financial disclosure form filed with FinCEN, a division of the U.S. Treasury. You have to file it if you had a financial interest in or signature authority over foreign financial accounts, and the total value of those accounts exceeded $10,000 at any time during the calendar year. The deadline is April 15, with an automatic extension to October 15.Traditional accounts like bank accounts, brokerage accounts, or mutual funds held overseas definitely count. But what about crypto? That’s where things get messy.
Right Now, Pure Crypto Accounts Don’t Count-But That Could Change
As of 2025, FinCEN’s official position is this: if your foreign account holds only cryptocurrency-no USD, no EUR, no Bitcoin Cash, no stablecoins tied to fiat-then you don’t have to report it on an FBAR. This comes from FinCEN Notice 2020-2, which still stands. It says virtual currency accounts aren’t reportable unless they hold other reportable assets alongside them.So if you have $8,000 in Bitcoin on Binance and $3,000 in Ethereum on KuCoin, and you never held any dollars or euros in those accounts, you’re technically not required to file. The $11,000 total doesn’t trigger the FBAR requirement-because the law doesn’t yet treat pure crypto accounts as financial accounts under the Bank Secrecy Act.
But here’s the catch: FinCEN has said repeatedly that it plans to change this. They’ve signaled they’re moving toward treating crypto holdings the same way they treat bank balances. Experts expect new rules to be finalized in 2025 or early 2026. When that happens, it likely won’t be retroactive-but it will apply to all future years. And if you didn’t keep records, you’ll be stuck.
Hybrid Accounts? They’re Definitely Reportable
This is where most people get tripped up. If your foreign crypto exchange account holds both cryptocurrency AND fiat currency-say, $2,000 in USDT and $9,000 in Euros-you’ve crossed the line. Even if your crypto balance dropped to $5,000 by year-end, the fact that you had $11,000 in total value at any point in 2025 means you must file an FBAR.Why? Because the account now contains reportable assets (the Euros) in addition to crypto. The presence of fiat turns the whole account into a financial account under FBAR rules. You don’t get to pick and choose what to report. The entire account is subject to disclosure.
Many users assume their crypto-only wallet on Binance is safe. But if they ever deposited USD to buy crypto, or withdrew EUR to their personal bank, they might have accidentally created a hybrid account. Exchange platforms don’t always make this clear. You need to check your account history.
Who Has to File? It’s Not Just You
You have to file if you’re a U.S. person-citizen, green card holder, or resident alien-and you meet the $10,000 threshold. But it’s not just about personal accounts. If you own more than 50% of a foreign corporation, partnership, or trust that holds crypto on a foreign exchange, you’re still on the hook. The IRS and FinCEN look through business structures.Signature authority matters too. If you can control funds on an account-even if you don’t own them-you might need to report. For example, if you’re the CFO of a U.S. company that uses a Binance corporate account, and you have the login to move funds, you could be required to file.
How Do You Even Calculate the Value?
Crypto prices swing wildly. One day your portfolio is worth $9,500. The next day, after a 15% pump, it’s $11,000. That single day triggers the requirement.You need to track the highest value of each foreign account during the calendar year, converted to U.S. dollars using the exchange rate on that day. You don’t average. You don’t use the year-end price. You find the peak value for each account and add them up.
For example:
- Account 1: Binance (BTC and ETH only) - peak value: $7,200
- Account 2: KuCoin (ETH and EUR) - peak value: $8,500 (includes $2,000 in EUR)
- Account 3: Bitfinex (BTC and USDT) - peak value: $4,000
Total: $7,200 + $8,500 + $4,000 = $19,700
You must file an FBAR because Account 2 is a hybrid account. Even if Accounts 1 and 3 are pure crypto, the hybrid account triggers the requirement for all foreign accounts you control.
What Happens If You Don’t File?
Non-willful failure to file can cost you $10,000 per violation. Willful violations? Up to $100,000 or 50% of the account balance-whichever is higher. These aren’t hypotheticals. The IRS has started auditing crypto users. In 2023, they issued 1,200 FBAR-related audit notices to crypto holders. Most didn’t know they were supposed to file.Even if you think the rules are unclear, the penalty risk isn’t. The IRS doesn’t care if you didn’t know. They care that you didn’t comply.
What Should You Do? Two Schools of Thought
There are two main paths crypto investors take:Path 1: Follow the Letter of the Law
Some tax professionals say: if FinCEN says crypto-only accounts aren’t reportable, then don’t file. File only if you have hybrid accounts. This reduces paperwork and avoids unnecessary filings. It’s legally defensible right now.
Path 2: Play It Safe
Others, including firms like CoinLedger and major crypto tax platforms, say: file anyway. Why? Because the rule change is coming. When it does, FinCEN won’t give you a free pass for past years. If you didn’t keep records, you’ll be scrambling to reconstruct your 2025 balances. If you filed now, you’re covered. It’s insurance.
Most high-net-worth crypto holders and institutional investors choose Path 2. They’re not trying to be extra cautious-they’re trying to avoid a $100,000 fine.
How to File (If You Decide To)
If you decide to file, here’s how:- Go to the BSA E-Filing System (FinCEN’s official portal).
- Create an account if you don’t have one. You can’t file as a third party unless you’re a registered tax preparer.
- Fill out FinCEN Form 114. You’ll need:
- Name of each foreign exchange (e.g., Binance, KuCoin)
- Address of the exchange’s headquarters (usually listed on their website)
- Account number or identifier (if available)
- Maximum value in USD for each account during 2025
- Your personal info (SSN, address, etc.)
- Submit electronically. Paper filings are no longer accepted.
- Keep copies for six years.
You don’t need to attach this to your tax return. It’s a separate filing.
What Records Should You Keep?
Regardless of whether you file, you need to keep detailed records:- Daily balances of all foreign crypto accounts in USD
- Exchange rates used (from a reliable source like CoinMarketCap or OANDA)
- Transaction history showing deposits, withdrawals, trades
- Proof of account ownership (screenshots of login, email confirmations)
- Whether each account held fiat currency at any time
Use crypto tax software like Koinly, CoinTracker, or ZenLedger. They can auto-calculate your peak balances and flag hybrid accounts. Manual tracking is possible, but it’s error-prone.
What’s Coming Next?
The Infrastructure Investment and Jobs Act of 2021 gave the IRS authority to require crypto brokers to report customer transactions. That’s already happening. Brokers like Coinbase must report to the IRS. Foreign exchanges? Not yet. But FinCEN is pushing hard to extend reporting to them.Expect new rules in 2025-2026 that will require FBAR reporting for all foreign crypto accounts, regardless of whether they hold fiat. The window to prepare is closing. Waiting for official guidance might be too late.
Bottom Line
You’re not required to file an FBAR for pure crypto accounts right now. But the rules are changing fast. If you had over $10,000 in foreign crypto accounts in 2025, you’re at risk-not because you broke the law, but because the law is about to catch up.Do you want to be the person who gets hit with a $10,000 penalty because they thought "it’s not required yet"? Or do you want to be the one who filed early, kept clean records, and slept well knowing they’re covered?
Don’t wait for the IRS to come knocking. Start tracking your balances today. Decide whether to file now-or at least get your records in order so you’re ready when the rules change.
Do I need to file an FBAR if I only hold Bitcoin on a foreign exchange?
If your foreign exchange account holds only Bitcoin or other cryptocurrencies and no fiat currency like USD or EUR, you are not currently required to file an FBAR under FinCEN Notice 2020-2. However, if your total value across all foreign crypto accounts exceeded $10,000 at any point in 2025, many tax professionals recommend filing anyway to prepare for upcoming regulatory changes.
What if I have crypto on multiple foreign exchanges?
You must add up the maximum value of all your foreign crypto accounts during the year. If the total exceeds $10,000 at any point, you may need to file-especially if any account holds fiat currency. Even if each account is under $10,000 individually, their combined peak value triggers the requirement.
Can I file an FBAR myself, or do I need a tax professional?
You can file an FBAR yourself using the FinCEN BSA E-Filing System. No tax professional is required. However, if you have complex holdings, multiple accounts, or hybrid accounts with fiat, working with a crypto-savvy tax advisor can help you avoid mistakes and reduce audit risk.
What’s the penalty for not filing an FBAR for crypto?
For non-willful violations, the penalty is up to $10,000 per violation. For willful violations, it’s the greater of $100,000 or 50% of the account balance at the time of the violation. The IRS has increased crypto-related audits, and penalties are being enforced.
Do I need to report my crypto wallet if it’s on a U.S.-based exchange?
No. FBAR only applies to foreign financial accounts. If your exchange is based in the U.S.-like Coinbase, Kraken, or Gemini-you don’t need to file an FBAR, even if your balance is over $10,000. However, you still need to report crypto transactions on your tax return (Form 1040).
Is there a deadline to file the FBAR for 2025?
Yes. The FBAR for 2025 is due by April 15, 2026, with an automatic extension to October 15, 2026. You don’t need to request the extension-it’s granted automatically. But you must file by October 15 to avoid penalties.
How do I find the address of my foreign crypto exchange for the FBAR?
Look on the exchange’s official website, usually in the "About Us," "Legal," or "Contact" sections. For example, Binance’s headquarters is in Malta. KuCoin is based in Seychelles. Use the official registered address, not the mailing address or customer support location.
Louise Watson
November 9, 2025 AT 06:04Don't file. It's not required. End of story.
Steven Lam
November 10, 2025 AT 22:18Why are we even talking about this? The government's gonna tax your socks off anyway. Just pay up and move on.
Noah Roelofsn
November 11, 2025 AT 02:19Actually, the FinCEN Notice 2020-2 is still in effect, and it explicitly excludes pure crypto accounts from FBAR reporting. The IRS hasn't amended the definition of 'financial account' under the Bank Secrecy Act to include crypto-only holdings. So legally, you're fine - but keep records anyway. The coming changes will be retroactive in practice, even if not in law.
Hybrid accounts? Definitely report. Any fiat balance, even $1, makes the whole account reportable. And yes, you have to track the peak value per account, not the average. Use CoinTracker or Koinly to auto-calculate that. Manual tracking is a nightmare.
Also, signature authority matters. If you can move funds on a corporate Binance account, even as CFO, you're on the hook. Don't assume ownership equals liability - control does.
Penalties aren't theoretical. In 2023, over 1,200 crypto FBAR audits were issued. Most people didn't know they were required to file - but ignorance isn't a defense. Non-willful is $10k. Willful? Up to $100k or 50% of balance. That’s life-changing money.
File now if you have hybrid accounts. For pure crypto? It’s a gamble. But if you're worth over $100k in crypto, why risk it? The rule change is coming in 2025-2026. When it does, you’ll wish you had records. Don’t be the guy who says, 'I didn’t know.' You knew. You just didn’t act.
And yes, you can file yourself. No CPA needed. Just go to BSA E-Filing. Keep screenshots of your exchange balances, exchange rates, and account IDs. Six years minimum. This isn’t optional if you want to sleep at night.
Sierra Rustami
November 12, 2025 AT 12:42Why are we letting foreign exchanges get away with this? If you're a U.S. citizen, you should report everything, everywhere, all the time. This is why America's losing its economic edge.
Glen Meyer
November 14, 2025 AT 03:46They're coming for your crypto. They always come for your crypto. You think you're safe? You're not. They'll take your Bitcoin and call it a 'financial account.' Wake up.
Christopher Evans
November 16, 2025 AT 00:49The legal ambiguity here is precisely why caution is warranted. While FinCEN's current guidance excludes pure crypto accounts, the trajectory of regulation is unambiguous. Maintaining detailed, timestamped records of account balances, exchange rates, and fiat activity is not merely prudent - it is a baseline duty for any U.S. person with international financial exposure.
Furthermore, the distinction between 'ownership' and 'signature authority' is legally significant and often misunderstood. Individuals with administrative access to corporate or trust-held foreign crypto accounts may be subject to reporting obligations regardless of beneficial ownership.
The BSA E-Filing System is accessible and free. The cost of non-compliance, even under non-willful interpretations, far exceeds the time required to file. Waiting for clarity is not a strategy - it is a liability.
Benjamin Jackson
November 17, 2025 AT 15:21Honestly? I filed anyway. Even though my accounts were pure crypto, I just didn’t want to stress about it later. Took me an hour with CoinTracker. I sleep better now. No regrets.
Liam Workman
November 18, 2025 AT 00:18Life’s too short to play regulatory roulette 🤷♂️
File the FBAR. Keep your records. Sleep like a baby.
They’re coming for the crypto - whether you like it or not. Better to be the person who was ready than the one who said, 'I didn’t know.'
And hey - if you’re using Binance or KuCoin, you’re already living on the edge. Might as well edge responsibly 😊
Sarah Scheerlinck
November 18, 2025 AT 19:16I appreciate how calm and thoughtful this post is. So many people panic, but the real issue is documentation. I’ve been tracking my balances daily since last year - even the ones under $10k. It’s not about fear. It’s about freedom. Knowing I’m covered lets me focus on building, not worrying.
Anthony Allen
November 19, 2025 AT 23:25My cousin in India just moved his crypto to Binance because he thought it was 'safe' from U.S. rules. He’s a green card holder. He has no idea. This post should be mandatory reading for every expat with crypto.