FBAR for NRIs: Reporting Your Indian Accounts (2026)
Most NRIs who have lived in the US for a few years have already encountered FBAR, even if they did not realize it at the time. Maybe a CPA asked whether you held any foreign accounts. Maybe TurboTax popped a question about foreign assets that you answered yes to and then never thought about again. Maybe someone in your group chat mentioned it casually and then everyone pretended they already understood it.
FBAR is the foreign account reporting requirement that catches more NRIs out than almost any other US tax rule, and it does so for a simple reason. It is not part of your tax return. It is a separate filing, with a separate agency, with its own threshold, its own form, and its own penalty structure. The IRS does not collect it. FinCEN does. And the penalty for missing it accidentally can be larger than the entire balance of the account you forgot to report.
This guide walks through what FBAR is, who has to file it, what counts toward the threshold, how to actually file, and what happens if you have missed it in past years. It is written for NRIs living in the US who hold Indian bank or financial accounts. It is informational, not tax advice. Anything ambiguous in your situation should go to a CPA who handles US-India returns.
What FBAR is, in plain terms
FBAR stands for Report of Foreign Bank and Financial Accounts. The form is called FinCEN Form 114. It is filed electronically through the BSA E-Filing System run by the Financial Crimes Enforcement Network, which is part of the US Treasury Department.
The form does not collect tax. It is an information return. The US government wants a list of foreign financial accounts that US persons control, and FBAR is how it gets that list. The income from those accounts is reported separately on your regular tax return (Form 1040 and, where relevant, Schedule B and Form 8938). FBAR is the disclosure piece, not the tax piece.
You file FBAR if you meet two conditions. First, you are a US person, which includes US citizens, green card holders, and tax residents under the substantial presence test. Second, the aggregate maximum value of your foreign financial accounts crossed USD 10,000 at any point during the calendar year. The threshold is not annual income. It is not annual balance. It is the highest value any combination of your foreign accounts reached, even for a single day.
That last part trips up NRIs constantly. A 1.2 million rupee balance for two hours on the day a Diwali bonus landed in your NRO account is enough to trigger the filing requirement, even if the balance is back to a sixth of that the next morning.
The USD 10,000 aggregate threshold, explained
The threshold is aggregate, not per-account. You add up the highest value each foreign account reached during the year, then convert to USD using the Treasury year-end exchange rate. If the total crosses USD 10,000, you file. If it does not, you do not.
A worked example for a typical NRI. You have an NRE savings account with a maximum balance during the year of INR 700,000, an NRO account with a maximum of INR 200,000, and a fixed deposit that hit a maximum of INR 150,000. The total is INR 1,050,000. At a year-end conversion rate of roughly 83 rupees to the dollar, that is about USD 12,650. You file FBAR.
If those same three accounts had maxed at INR 700,000 combined, you would be under the threshold and not required to file. There is no partial-credit zone, but the rule cuts both ways: a single dollar over the line and you owe the full filing.
| Account | Max value during year | USD equivalent |
|---|---|---|
| NRE savings | INR 700,000 | ~USD 8,400 |
| NRO savings | INR 200,000 | ~USD 2,400 |
| Fixed deposit (NRE) | INR 150,000 | ~USD 1,800 |
| Aggregate | INR 1,050,000 | ~USD 12,650 |
| Threshold | USD 10,000 | |
| File FBAR? | Yes |
What kinds of accounts count
Almost every account an NRI typically holds in India counts as a foreign financial account for FBAR. The list is broader than most people assume.
NRE and NRO bank accounts count. Regular Indian savings or current accounts you held before moving and never closed count. Fixed deposits in your name count. Demat accounts holding Indian shares, mutual fund holdings on the Indian platforms, PPF accounts, Indian brokerage accounts, and foreign pension or provident fund balances where you have signature authority all count. So do joint accounts where you are a signatory, even if the money is not “yours” by family understanding. So do accounts you have signature authority over but no beneficial ownership of — accounts in a parent’s name that you can operate on their behalf, for example.
What does not count is narrower. Physical real estate is not a financial account. Gold or other physical assets held outside an account are not. Direct holdings of foreign stock certificates that are not in a brokerage account fall outside FBAR but may still be reportable on Form 8938 if you cross the higher thresholds there.
Reality Check: NRE vs NRO does not change FBAR A surprising number of NRIs assume NRE accounts are somehow off the FBAR list because they hold “foreign-source” income. They are not. Both NRE and NRO accounts are foreign financial accounts under FBAR rules. Both count toward the aggregate threshold. Both go on the form.
How and when to file
FBAR is filed at bsaefiling.fincen.treas.gov. There is no fee. The form itself is FinCEN Form 114 and it takes most people thirty to sixty minutes the first time, faster in later years.
The filing deadline is April 15 of the year after the calendar year being reported. So FBAR for the 2025 calendar year is due April 15, 2026. There is an automatic extension to October 15 with no separate extension request required. You do not need to file Form 4868 or any other form to claim it. Even if your federal tax return is on extension, FBAR’s automatic October 15 deadline applies independently.
The form asks for the following for each account: name and address of the foreign financial institution, account number, account type, and the maximum value during the year. There is no income detail — that goes on your 1040, not FBAR. For maximum value, the Treasury Department’s year-end exchange rate is the safe conversion to use; you can find it on the Bureau of the Fiscal Service website each January.
You file FBAR for yourself. Your spouse files their own if their accounts independently cross the threshold. A married couple where both spouses are US persons and only one has accounts over USD 10,000 generally each file their own FBARs. There are narrow joint-filing scenarios but they are exceptions; assume separate filings unless a CPA confirms otherwise.
Travel Tip for new NRIs If this is your first US tax year as a green card holder or resident alien, run the FBAR aggregate calculation alongside your regular tax prep, not after. Forgetting about it until June is the most common way the deadline gets blown, because it is not on the 1040 checklist most tax software walks you through.
Penalties for missing it
The FBAR penalty structure is harsher than the rule itself, which is part of why this filing deserves attention even when balances feel small.
For non-willful failures to file — you genuinely did not know — the civil penalty caps at roughly USD 12,000 to USD 16,000 per violation, adjusted annually for inflation. A “violation” has historically been interpreted as per form, not per account, though there has been litigation and the rules can shift.
For willful failures — you knew and chose not to file — the penalty rises to the greater of about USD 161,000 or 50 percent of the highest account balance, per year of violation. Criminal penalties on top of that are technically available for the most extreme cases, including fines up to USD 500,000 and up to ten years of imprisonment, though they are rare.
The practical implication for an NRI who missed FBAR for one or two prior years out of inattention is rarely the worst-case scenario. The IRS and FinCEN have programs for catching up on unfiled FBARs, including the Streamlined Filing Compliance Procedures for non-willful taxpayers and the Delinquent FBAR Submission Procedures for cases where all income was already reported on returns. Both are designed to bring people back into compliance without the maximum penalty stack. A CPA who handles cross-border returns can tell you which one fits your situation.
How a cross-border payments app fits into the picture
This is the spot where a quick clarification matters. FBAR is about accounts you hold, not money you transfer. Using a cross-border payments app to send rupees from your US bank to a recipient in India does not create a foreign financial account in your name. The funds leave your US account and land in the recipient’s Indian account. Neither of those is a new FBAR-reportable account for you.
Where FBAR comes in is if you already have an Indian bank account in your name — an NRE, NRO, or savings account you kept open after moving — and that account’s balance at any point in the year crosses the threshold. The transfer mechanism is irrelevant to FBAR. Whether you sent the rupees via a bank wire, a remittance service, or a cross-border payments app, what FBAR cares about is the account, not the rail.
If you do hold Indian accounts in your name, picking a cross-border payments app that is transparent and FinCEN-registered keeps your transfer records clean. Sliq Pay is a cross-border payments app operated by Sliq Pay Inc., based in Mountain View, California, with NMLS ID 2714589 and MSB Registration 31000298221871. Transfers happen at mid-market FX with no markup, and you can pull a complete transaction history out of the app, which makes the year-end paperwork easier whether you are filing FBAR or filling out Schedule B.
FAQs
Do I file FBAR if my account is jointly held with an Indian relative who is not a US person? Yes, if you are a US person and you have signature authority or ownership of the account. The relative’s status does not exempt you. You report the full account, not your assumed share of it.
Does FBAR apply if my Indian account is below INR 800,000? That works out to roughly USD 9,600 at typical 2025 conversion rates, which is below the USD 10,000 threshold. If that is your only foreign account, you would not need to file. If you have any other foreign accounts, aggregate them all before deciding.
Is FBAR the same as Form 8938? No. Form 8938 is the Statement of Specified Foreign Financial Assets filed with the IRS as part of your tax return, with higher thresholds (USD 50,000 to USD 200,000 depending on filing status and residency). You may need to file both. FBAR goes to FinCEN; 8938 goes to the IRS. Same underlying accounts, two different forms.
What if my Indian account earned interest that I forgot to report? That is a separate issue from FBAR. Interest goes on Schedule B of your 1040 and is taxable in the US, with credit available for taxes paid in India under the US-India tax treaty. If you missed both, the Streamlined Filing Compliance Procedures cover both kinds of past errors at the same time. A CPA can walk you through.
I closed my Indian account mid-year. Do I still file FBAR? Yes, if the account’s maximum value at any point during the year crossed USD 10,000. Closing it does not erase the calendar-year reporting requirement.
Can a cross-border payments app help me with FBAR filing? No. Filing FBAR is your responsibility, and it goes to FinCEN. What an app like Sliq Pay can do is keep your year-end transfer records clean and easy to export, which makes the supporting paperwork less painful. Worth setting up before the trip if you are going to be sending money to India regularly.
Is the threshold per year or all-time? Per calendar year, calculated as the aggregate maximum balance across all foreign financial accounts.
Before you go
FBAR is a once-a-year nuisance with high upside for getting it right. It takes most NRIs less than an hour the first time, and the penalty for ignoring it scales fast. If your Indian accounts’ aggregate maximum balance crossed USD 10,000 at any point in the calendar year, you file by April 15 (or by October 15 under the automatic extension). The accounts go on FinCEN Form 114 at bsaefiling.fincen.treas.gov. Income from those accounts is a separate matter on your 1040.
A clean cross-border payments setup makes the supporting documentation easier on both sides of the filing. Sliq Pay’s full transaction history exports cleanly, mid-market FX makes the year-end numbers easier to reconstruct, and the US side of the transfer chain is regulated and FinCEN-aware from the start.
Disclaimer — The information provided on this blog is for general informational purposes only and does not constitute legal, financial, tax, or professional advice. Product features, pricing, eligibility, and availability may vary by country, user type, regulatory requirements, and are subject to change.
Please refer to Sliq Pay’s Terms of Use and official product pages for the most accurate and up-to-date information. Sliq Pay makes no representations or warranties regarding the completeness, accuracy, or reliability of the content.
