FBAR and FATCA Reporting for Indian Bank Accounts

Short answer

If you're a US citizen, green card holder or tax resident, your NRE, NRO, FCNR, PPF, EPF, demat and similar Indian accounts count towards two separate US reports. Combined balances above USD 10,000 at any time trigger the FBAR, filed with FinCEN by April 15, 2027, automatically extended to October 15, 2027. A second, higher threshold can also trigger Form 8938 with your return.

Is this you? This guide covers reporting Indian accounts once you're a US person. The extra US tax on Indian mutual funds is a separate filing: see PFIC and Indian mutual funds. Not a US person yet? Neither report applies.

This assumes you're a US person for the year: a citizen, a green card holder, or resident under the substantial presence test. Moving back this year? Check your residency status first, because the answer can change.

This guide is part of our guide to US and India tax for Indians living in America. Here we cover exactly two US filings: the FBAR and Form 8938, for Indian accounts you hold, or can merely operate, once you’re a US person.

Which Indian accounts count

The Report of Foreign Bank and Financial Accounts (FBAR) and Form 8938 both look at “foreign financial accounts” and “specified foreign financial assets” far more broadly than just savings accounts. If it holds money or something money-like, and it isn’t in the United States, assume it counts until you can rule it out:

Account	FBAR	Form 8938	Note
NRE and NRO savings accounts, current accounts, fixed deposits	Yes	Yes	Counts whether or not the interest is taxable in India
FCNR fixed deposits	Yes	Yes	Same as any other foreign deposit account
PPF	Likely yes	Likely yes	A deposit account with a government-linked institution; not a US-recognised retirement plan
EPF	Likely yes	Likely yes	Maintained on your behalf by a fund body; same reasoning as PPF
Demat account (shares, bonds held electronically)	Yes	Yes, as an account	A custodial account; what’s inside it is reported through the account, not asset by asset
Mutual fund folio	Yes	Yes	Also a PFIC — see our PFIC and Indian mutual funds guide for the extra tax, separate from this reporting
Life insurance or ULIP with cash value	Yes	Yes	A term policy with no cash surrender value doesn’t count
Joint account with a parent or other relative in India	Yes, in full	Yes, in full	Being a joint owner of record means the whole balance is yours for reporting, not half

Two categories of ownership put an account on your FBAR, and either is enough on its own. A financial interest means you’re the owner of record, or the actual owner even if someone else’s name is on it. Signature authority means you can control what happens to the money — move it, close the account, instruct the bank — even if you don’t own a rupee of it: a parent’s account you can operate under a power of attorney, for instance, or an account you manage for your employer.

Do you need to file?

The FBAR has one threshold, tested at any time in the year, however many accounts you have: your combined accounts above USD 10,000 means every one of them goes on the report, not just the ones that pushed you over. Money you send over from the US counts from the day it lands; how you send it matters only for a separate charge, the US remittance tax, which applies to transfers paid in cash, by money order or by cashier’s check.

Form 8938 has four thresholds instead of one, because they depend on your filing status and where you live:

Your situation	Threshold at year end	Threshold at any time in the year
Unmarried, living in the US	USD 50,000	USD 75,000
Married filing jointly, living in the US	USD 100,000	USD 150,000
Unmarried, living outside the US	USD 200,000	USD 300,000
Married filing jointly, living outside the US	USD 400,000	USD 600,000

“Living outside the US” for this table is the IRS’s own test in the Form 8938 instructions, not the Indian residency tests used elsewhere on this site. You count as living abroad only if your tax home is in a foreign country and either you were physically present in foreign countries for at least 330 full days in a 12-month period ending in the tax year, or you’re a US citizen who was a bona fide resident of a foreign country for the whole tax year. Most people reading this, living and working in the US, use the lower “living in the US” thresholds. In the year you move to or from the US, check the test against your actual dates: the 330 days can straddle two tax years.

Converting maximum values

For each account, find its highest balance at any point in the year from the bank or fund house’s own statements, in rupees. Convert that one figure to dollars using the US Treasury’s exchange rate for 31 December of that year — not the rate on the day the balance peaked, and not whatever rate your bank quotes. Form 8938 uses the same Treasury year-end rate for every value it asks for, including the maximum value during the year, even for an account you closed before 31 December. Add every account together, in dollars, to test against both thresholds.

How the two reports overlap

They ask about the same accounts but aren’t the same filing, and one doesn’t excuse you from the other:

Different recipient. The FBAR goes to FinCEN, the Treasury’s financial-crimes unit, on its own form. Form 8938 goes to the IRS, attached to your federal return.
Different scope. The FBAR only covers foreign financial accounts. Form 8938 also covers some assets that aren’t in an account at all — foreign fund or company interests you hold directly, for instance — which is one reason its threshold is higher.
No double listing, but double counting. A mutual fund you already report on Form 8621 for its PFIC status isn’t listed again on Form 8938 — but it still counts towards that form’s threshold, and it’s still on the FBAR regardless.
Independent deadlines. An extension on your federal return extends Form 8938. It does nothing for the FBAR, which has its own automatic extension below.

What you need before you start

What	Who	When
Every account you own, co-own or can operate in India, including PPF, EPF and demat	You	Before the deadline
Statements or passbooks covering the whole calendar year, to find each account’s highest balance	Bank, post office, EPFO, fund house, insurer	Each January
Each account’s number and the institution’s name and address	You	Before you file
Access to FinCEN’s BSA E-Filing System	You	Before the FBAR deadline

Steps

List every account, and who’s on itInclude accounts only in a parent’s name that you can operate, and accounts where you’re a joint holder but didn’t fund them.
Get each account’s highest balance for the yearFrom statements, not memory; ask the institution for a year-end or annual statement if it doesn’t send one.
Convert to dollars at the Treasury’s year-end rateUse the same rate for every account, for the same calendar year.
Add them up and test both thresholdsCombined value against USD 10,000 for the FBAR, and against your row in the table above for Form 8938.
File the FBAR electronically with FinCENEvery account goes on it once you’re over the threshold, not only the ones that pushed you over.
April 15, 2027, extended to October 15, 2027
File Form 8938 with your return, if you’re over its thresholdAttach it to your federal return; its due date follows your return, including any extension you take.
Keep your recordsHold on to the statements and your working for at least five years.

After you file: deadlines and what can go wrong

The FBAR is due April 15, 2027, but FinCEN grants everyone an automatic extension to October 15, 2027, with no request needed — it simply applies. Form 8938 has no separate extension: it follows your federal return’s own due date and extensions.

Common mistakes

Treating “bank accounts” narrowly, and leaving PPF, EPF, insurance policies and demat holdings off the FBAR because they don’t look like a savings account.
Forgetting an account you don’t own but can operate, such as a parent’s account you hold power of attorney over.
Converting each account at a different, convenient exchange rate instead of the Treasury’s single year-end rate.
Assuming Form 8938 replaces the FBAR, or that filing one covers the other — they go to different agencies and neither substitutes for the other.
Waiting to see if the IRS notices missed years, instead of using the Streamlined procedures below while you’re still eligible (they close to you once the IRS contacts you).

If you’ve missed years

What’s left depends on whether you also missed reporting the income:

Properly reported the income, just missed the FBAR itself? The IRS withdrew its separate delinquent FBAR submission procedures on 1 July 2026, so there’s no longer a published route that promises no penalty. You can still file the late FBARs electronically with a statement explaining the reason. The non-willful penalty doesn’t apply where there was reasonable cause, which is where a CPA or Enrolled Agent earns their fee.
Missed the income too, and it wasn’t willful? The Streamlined Filing Compliance Procedures cover both the FBARs and the underlying returns, for three years of returns and six of FBARs. The foreign version accepts late original returns or amended ones; the domestic version is only for people who already filed their returns, and takes amended returns, with a signed certification that the failure wasn’t willful. The foreign version, for those who meet a non-residency test, waives the offshore penalty entirely; the domestic version, for those living in the US, instead carries a 5% penalty on the highest year-end combined value of the accounts and assets involved. Form 8938 filings you missed can go through the related delinquent international information return submission procedures.

The Streamlined procedures and the delinquent information return procedures were open when this was checked in September 2026. The IRS withdrew the delinquent FBAR route with little notice, so check the current pages before you rely on either, and don’t delay once you know you’re behind.

When to get a CPA or Enrolled Agent

Get one before you file anything if you’re more than a year behind on either report, if any account is jointly held with someone who isn’t a US person, if you’re unsure whether an Indian retirement account like PPF or EPF counts, or if the value involved is large enough that the non-willful and willful penalties above would actually hurt. A CPA or EA who handles US persons with Indian accounts can also tell you which of the fix-up procedures fits your facts — picking the wrong one, or none, is the costly mistake.

Next steps

Questions people ask

Do I have to file both the FBAR and Form 8938?

You can owe either, both or neither — they're separate reports to separate agencies, with separate thresholds. The FBAR goes to FinCEN once your combined foreign accounts pass USD 10,000 at any time in the year. Form 8938 goes to the IRS with your return, only once your specified foreign assets pass a much higher threshold that depends on whether you're married and where you live. Many people file the FBAR for years before their assets ever reach the Form 8938 level.

My NRE fixed deposit is tax-free in India — does it still count?

Yes. Whether India taxes an account has no bearing on whether the US wants to know about it. NRE, NRO and FCNR accounts are all foreign financial accounts wherever they sit, and every rupee in them, converted to dollars, goes into your combined balance for both reports.

Do my PPF and EPF count, since they're retirement savings?

Probably, and most advisers report both, but this is a grey area: no IRS or FinCEN guidance names PPF or EPF. A PPF account is held at a bank or post office, which fits FinCEN's broad definition of a financial account well. EPF is run by the EPFO, a statutory fund body, so the fit is less certain, but leaving it off is the riskier choice. Neither is a US-recognised retirement plan, so the FBAR's exception for accounts like IRAs doesn't help, and the India–US tax treaty doesn't remove either report. For Form 8938, EPF is usually treated as an interest in a foreign pension plan; some argue its pension element is a government social-security-type scheme, which the form excludes, but that's untested. Ask a CPA or Enrolled Agent how to treat yours.

I'm only a joint holder on my parents' account in India — does that count?

Usually, yes, and it can catch people out. If your name is on the account as a joint owner, you have a financial interest in the whole balance, not just "your share", for both reports. If your name isn't on the account but you can operate it — move money, close it, give instructions to the bank — that's signature authority, which by itself is enough to put it on the FBAR even though you'd never claim to own a rupee of it.

How do I convert my account balances to dollars?

For the FBAR, use each account's highest balance during the year in rupees, then convert that one figure using the US Treasury's exchange rate for the last day of the calendar year — not the rate on the day the balance peaked, and not your bank's rate. Form 8938 uses the same Treasury year-end rate for every value, the maximum value included, even for an account you closed during the year.

What if I've never filed and I'm several years behind?

Don't just start filing this year and hope no one asks about the rest. If you also missed reporting the Indian income, or you're not sure, the Streamlined Filing Compliance Procedures are built for exactly this and can head off the larger penalties below. If the income was properly reported and you only missed the FBAR, you can still file the late FBARs with a reason, but the IRS withdrew its published penalty-free route for that on 1 July 2026. Either way, talk to a CPA or Enrolled Agent before you file anything.

Are the penalties really per account, or per year?

It depends which kind. A non-willful miss is capped at USD 16,536 per FBAR — that is, per year you should have filed, however many accounts were on it — since the Supreme Court's 2023 ruling in Bittner v. United States rejected the government's per-account reading, and no penalty applies if the miss was due to reasonable cause. A willful violation is far worse: it can cost up to the greater of USD 165,353 or 50% of the account's balance at the time of the violation, per account.

Sources

Update log

28 September 2026Linked the new US remittance tax guide from the FBAR threshold section.