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

If you hold cryptocurrency on a foreign exchange and your total balance crossed $10,000 at any point in 2025, you might be required to file an FBAR. It’s not optional. It’s not a suggestion. It’s a legal obligation enforced by the U.S. government - and the penalties for ignoring it can be brutal.

What Exactly Is an FBAR?

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 must file FinCEN Form 114 if, at any time during the calendar year, the combined value of all your foreign financial accounts exceeded $10,000. That’s not per account. That’s the total of everything you own abroad - bank accounts, investment accounts, and yes, cryptocurrency accounts under certain conditions.

The deadline is April 15, but you automatically get an extension to October 15. No paperwork needed to get it. Just file by then.

Crypto Accounts and the $10,000 Rule

Here’s where it gets messy. In 2020, FinCEN issued a notice saying foreign cryptocurrency accounts aren’t reportable on FBAR - unless they also hold traditional money like euros, yen, or dollars. That means if you only hold Bitcoin, Ethereum, or Solana on Binance, KuCoin, or Kraken (outside the U.S.), you’re technically not required to report them under current rules.

But here’s the catch: if your account holds both crypto and fiat currency - say, $5,000 in ETH and $7,000 in EUR - you’re now in the clear for reporting. That hybrid account triggers the FBAR requirement. The $10,000 threshold applies to the total value of all reportable assets in that account, not just the crypto.

And don’t assume your crypto balance is safe just because it’s on a "decentralized" platform. If the exchange is based outside the U.S. and you have control over the private keys or withdrawal rights, it counts as a foreign financial account. That includes platforms like Bybit, Bitstamp, or even crypto wallets linked to foreign custodians.

Who Has to File?

You’re required to file if you’re a U.S. person - that includes citizens, green card holders, and residents who meet the substantial presence test - and you had a financial interest in or signature authority over any foreign account that hit $10,000 at any time in 2025.

Financial interest means you own the account, or you’re the beneficiary of a trust or corporation that owns it. Signature authority means you can control withdrawals or transfers, even if you don’t own the money. So if you’re a co-signer on a crypto wallet with a friend in Germany, and you can move funds, you may need to report it.

It doesn’t matter if you didn’t sell, trade, or cash out. The mere existence of the balance above $10,000 triggers the requirement. Even if your Bitcoin was worth $12,000 on June 3rd and dropped to $8,000 the next day, you still had to report it.

The Big Gray Area: Should You Report Anyway?

Many tax pros - especially those who specialize in crypto - say you should file even if you’re not legally required to. Why? Because FinCEN has said they’re working on new rules to include crypto as a reportable asset. They’ve been hinting at this for years. In 2025, it’s not a matter of if, but when.

Think of it like this: if you’re holding $15,000 in crypto on Binance.com and you wait for the rule change, you could be hit with retroactive penalties for not reporting in 2023, 2024, and 2025. Penalties for willful non-compliance can reach $100,000 or 50% of the account balance - whichever is higher. For non-willful violations, it’s $10,000 per violation. That’s per year, per account.

Conservative filers - the kind who work with firms like CoinLedger or CryptoTaxCalculator - recommend filing even for pure crypto accounts. It’s not required now, but it’s a shield against future audits. If you’ve kept records and filed voluntarily, the IRS is far more likely to treat you as cooperative, not careless.

How to Calculate Your Crypto Balance

You can’t just look at your wallet balance and guess. You need the highest value in U.S. dollars for each account during the year.

For example:

• On January 15, your ETH balance was worth $8,000
• On March 22, it spiked to $14,500
• On November 10, it dropped to $6,200

You report $14,500 - the peak value. Even if you only held that high for one day, that’s the number that matters.

Use tools like Koinly, CoinTracker, or even a detailed spreadsheet with daily price data from CoinGecko or CoinMarketCap. Don’t rely on exchange statements - they don’t always show accurate historical values. You need the exact USD equivalent on the day your balance peaked.

What If You Have Multiple Accounts?

Add them all up. If you have $4,000 on Binance, $3,500 on KuCoin, and $3,000 on Bitstamp, your total is $10,500. You’re required to file. It doesn’t matter that no single account hit $10,000. The rule is about the aggregate value of all your foreign accounts.

And yes - you have to list each one separately on FinCEN Form 114. Name the exchange, the country it’s based in, and the account number (if available). Some exchanges don’t give you account numbers. In that case, use your email or user ID, and note that it’s a crypto account. Be specific. Don’t write "crypto wallet." Write "Binance.com, Singapore, User ID: abc123."

How to File

You file electronically through the BSA E-Filing System. No paper forms. No exceptions. You can file yourself, or hire a tax professional who’s registered as a BSA E-Filer. Most accountants aren’t set up for this - you need someone who’s trained in FinCEN reporting.

The form asks for:

• Your personal info (name, SSN, address)
• Details for each foreign account: institution name, country, account number
• The maximum value of each account in USD during the year
• Whether you have signature authority

It takes about 15-30 minutes to complete if you have your records ready. No payment. No fee. Just accuracy.

What Happens If You Don’t File?

The IRS and FinCEN are getting serious. They’ve been cross-referencing data from U.S.-based exchanges like Coinbase and Kraken with foreign exchange data. They know who’s holding crypto overseas. They know the balances. They’re building case files.

If you didn’t file and they catch you:

• Non-willful violation: $10,000 per year, per account
• Willful violation: up to $100,000 or 50% of the account balance - whichever is higher

There’s no statute of limitations for FBAR violations. That means if you never filed for 2020, 2021, 2022, 2023, and 2024 - and you’re caught in 2025 - you could owe $50,000 in penalties. That’s not a hypothetical. It’s happened.

There’s a relief program called the Streamlined Filing Compliance Procedures, but it only works if you’re not under audit. If you’ve been contacted by the IRS, you’re out of luck.

What’s Coming Next?

FinCEN has signaled it will soon require FBAR reporting for all foreign crypto accounts - even pure ones. The Infrastructure Investment and Jobs Act of 2021 already gave them the authority. The proposed rule changes are expected to go into effect in 2026 or early 2027.

That means if you wait until 2026 to file, you might be forced to report 2023, 2024, and 2025 retroactively. That’s why tax experts say: file now, even if you’re not required. It’s not about being perfect today. It’s about protecting yourself tomorrow.

What You Should Do Right Now

1. List every foreign crypto account you’ve held in 2025 - even if you closed it. Include exchanges, wallets with foreign custodians, and DeFi platforms with overseas entities.

2. Calculate the peak value of each in USD during the year. Use reliable price data.

3. Add them all up. If the total is $10,000 or more, you need to file.

4. Even if you’re under $10,000, keep detailed records. You’ll need them if the rules change.

5. File by October 15, 2025 - or sooner if you’re feeling cautious.

If you’re unsure, hire a crypto-savvy CPA or tax attorney. Don’t trust a general accountant. This isn’t standard tax stuff. It’s a niche compliance area with real legal risk.