FBAR Requirements for Crypto Accounts Over $10,000 in 2025

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 catch: you might not be. The rules are confusing, changing fast, and many people are filing unnecessarily-or worse, not filing when they should.

What Is an FBAR, Really?

FBAR stands for Foreign Bank and Financial Account Report. It’s not a tax form. It’s a report filed with FinCEN, a branch of the U.S. Treasury, to track money held overseas. You have to file FinCEN Form 114 if you have 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.

This applies to bank accounts, brokerage accounts, mutual funds, and yes-cryptocurrency accounts. But only under certain conditions.

Are Crypto Accounts Reportable Right Now?

As of 2025, the answer is: only if they’re mixed accounts.

FinCEN issued Notice 2020-2, which says that pure cryptocurrency accounts-those holding only Bitcoin, Ethereum, or other digital assets-are not currently required to be reported on FBARs. This hasn’t changed. If your account on Binance.com holds only BTC and ETH, and nothing else, you don’t have to file an FBAR… yet.

But if that same account also holds Euros, USD, or any other fiat currency, it becomes a hybrid account. And hybrid accounts? They’re reportable. Period. Even if the fiat portion is just $100, and your crypto is worth $9,900, the combined total triggers the $10,000 threshold.

What Counts as a "Foreign" Account?

The key word here is foreign. If you’re using a U.S.-based exchange like Coinbase, Kraken, or Gemini, you don’t need to file an FBAR-even if you have millions in crypto. Those are domestic accounts.

Foreign means the exchange is based outside the U.S. That includes:

• Binance.com (based in Malta, Cayman Islands)
• KuCoin (based in Seychelles)
• Bitfinex (based in the British Virgin Islands)
• Bybit (based in Dubai)
• Any exchange that doesn’t have a U.S. entity registered with FinCEN or the SEC

Even if you live in the U.S. and use your U.S. phone number, if the exchange’s legal headquarters is overseas, it’s a foreign account for FBAR purposes.

How Do You Calculate the ,000 Threshold?

It’s not the average balance. It’s not the balance on December 31. It’s the highest value your accounts reached at any single point during the year.

Let’s say you had:

• Bitcoin worth $6,000 on January 15
• Bitcoin worth $12,000 on March 10
• Bitcoin worth $8,000 on October 5

You had one day-March 10-when your account balance crossed $10,000. That triggers the requirement. If you had another foreign account with $3,000 in ETH, your total becomes $15,000. Even if they’re on different exchanges, you add them together.

Valuation is tricky. You need to track daily prices in USD. Most people use crypto tax software like Koinly, CoinTracker, or ZenLedger to auto-calculate max balances. Manual spreadsheets work too-but they’re error-prone.

What If You Have Signature Authority?

You don’t have to own the account to be responsible. If you can move the crypto-even if it’s your company’s wallet, or a trust you manage-you have signature authority. That counts.

Example: You’re the CFO of a startup that holds Bitcoin on a Binance corporate account. Even if you don’t personally own the BTC, if you can sign off on transfers, you’re required to report it on your personal FBAR.

This also applies to joint accounts. If you and your spouse each have a $7,000 balance on separate foreign exchanges, you still have to report the total-$14,000.

Should You File Even If You’re Not Required?

This is where things get messy.

Some tax professionals say: Don’t file unless the law says so. They point to FinCEN’s own notice and say: Why risk an audit or extra paperwork if you’re not legally obligated?

Others say: File anyway. Why? Because FinCEN has been clear they plan to change the rules. In Notice 2020-2, they wrote: “FinCEN intends to propose a rule to include virtual currency as a reportable account.” That was three years ago. Now, in 2025, with the IRS cracking down on crypto, and new broker reporting rules kicking in, it’s not a matter of if-it’s when.

Here’s the risk: If the rule changes next year and you didn’t file for 2025, you could be hit with penalties for failure to file for the prior year. Penalties start at $10,000 per violation and can go up to 50% of the account balance if it’s deemed willful.

Conservative filers-especially those with over $50,000 in foreign crypto-are already filing. They’re treating it like a safety net. If you’re planning to stay in the U.S. long-term, own crypto for years, or might ever be audited, filing now saves you from a bigger problem later.

What Happens If You Don’t File?

The IRS doesn’t cross-check crypto accounts with FinCEN yet. But they’re building the systems. In 2024, the IRS sent out 15,000 crypto audit letters. Many asked for foreign exchange records. If you’re caught, you’ll owe:

• Non-willful penalty: $10,000 per year (can be waived if you can prove you didn’t know)
• Willful penalty: Up to 50% of the account balance per year, or $100,000, whichever is higher
• Back taxes + interest on unreported gains

There’s no statute of limitations for FBAR non-compliance. If you never filed and the IRS finds out in 2030, you can still be penalized for 2025.

How to File (If You Need To)

If you decide to file:

1. Go to the BSA E-Filing System (no login needed)
2. Fill out FinCEN Form 114
3. For each foreign crypto account, list:
• Exchange name (e.g., Binance.com)
• Country of registration
• Account number (if available-some exchanges don’t provide one)
• Max value in USD during 2025
4. Submit electronically. Paper filings are no longer accepted.

You have until April 15 to file, with an automatic extension to October 15. No request needed.

Professional tax preparers must register as BSA E-Filers to file for clients. If you use an accountant, make sure they’ve done this before. Many haven’t.

What Should You Do Right Now?

Here’s a simple action plan:

• If you have pure crypto accounts only (no fiat): You’re not required to file-but start tracking your max balances for 2025. Save screenshots, export transaction histories, and use tax software to record daily values.
• If you have hybrid accounts (crypto + USD, EUR, etc.): File an FBAR. Don’t wait.
• If you have over $10,000 total across multiple foreign accounts: Even if you’re unsure, file. The cost of filing is minimal. The cost of getting caught later is huge.
• If you’re unsure: Get a second opinion from a crypto-savvy CPA or tax attorney. Don’t rely on your regular accountant unless they specialize in digital assets.

Don’t wait for the IRS to catch you. The rules are changing. The data is being collected. The penalties are real. And if you’re holding crypto overseas, you’re already in the crosshairs.