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 skipping 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 financial disclosure form filed with FinCEN, a branch of the U.S. Treasury. You file it if you have a financial interest in or signature authority over foreign financial accounts, and the total value of all those accounts hit $10,000 or more at any time during the calendar year.

That $10,000 threshold isn’t per account. It’s the sum of every foreign account you own or control. So if you have $6,000 on Binance and $5,000 on KuCoin, you’ve crossed the line. Even if it was only for one day in June, you still need to file.

Crypto Accounts and the FBAR Loophole (That Might Not Last)

Here’s where things get messy. Until now, FinCEN has said that pure cryptocurrency accounts - meaning accounts holding only Bitcoin, Ethereum, or other digital assets with no fiat currency like USD or EUR - don’t count as reportable under FBAR rules. This comes from FinCEN Notice 2020-2, which explicitly states that virtual currency accounts aren’t reportable unless they also hold traditional financial assets.

So if your account on Binance.com holds only BTC and ETH? Under current rules, you don’t need to report it. But here’s the catch: FinCEN has said they plan to change this. They’ve been clear that they intend to require FBAR reporting for crypto accounts in the near future. That means if you wait until the rules change to start filing, you could be on the hook for back taxes and penalties.

Hybrid Accounts Are Always Reportable

If your foreign crypto account also holds dollars, euros, or any other fiat currency, it’s no longer a "pure" crypto account. It’s a hybrid account - and hybrid accounts are 100% reportable, no exceptions.

For example:

• You have a Binance account with 0.5 BTC and $8,000 in USD → Reportable
• You have a KuCoin account with 2 ETH and €2,000 → Reportable
• You have a Bitfinex account with only 10 LTC → Not reportable (for now)

Even if your crypto holdings are worth $50,000, if there’s no fiat in the account, you’re currently exempt. But if you’ve got even $1 in USD alongside your crypto, you’re in the reporting zone.

Who Has to File?

You must file if you’re a U.S. person - that means:

• A U.S. citizen
• A U.S. resident alien
• A green card holder
• A person who meets the Substantial Presence Test (spends enough time in the U.S. over three years)

You also have to file if you have signature authority over a foreign account - even if you don’t own the money. For example, if you’re the CFO of a company that holds crypto on a foreign exchange and you can authorize transfers, you’re responsible for filing.

Same goes if you control an account through a business you own. If you own more than 50% of a corporation or trust that holds crypto on a foreign exchange, you’re treated as having a financial interest in that account.

How to Calculate Your ,000 Threshold

Crypto prices swing wildly. One day your portfolio is worth $9,500. The next day, after a Bitcoin rally, it’s $12,000. That’s enough to trigger the FBAR requirement.

You need to track the highest value your foreign crypto accounts reached at any single point during the year. Not the average. Not the year-end balance. The peak.

Use a tool like CoinLedger, Koinly, or even a detailed spreadsheet to log daily balances in USD. Don’t guess. Don’t assume. If you can’t prove your highest balance was under $10,000, you’re risking a penalty.

What Happens If You Don’t File?

The IRS doesn’t just send a reminder. They come after you.

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

Willful means you knew you were supposed to file and chose not to. Even if you didn’t know the rules, the IRS can still argue you should’ve known - especially if you’ve been in crypto for years.

There’s no statute of limitations for FBAR violations. That means if you didn’t file in 2021 and the IRS finds out in 2025, they can still penalize you. The clock doesn’t start ticking until you file.

Should You File Even If You’re Not Required?

This is where tax professionals split down the middle.

One side says: Wait for the rules to change. FinCEN’s 2020 notice is clear. Pure crypto accounts aren’t reportable. Filing now is unnecessary work.

The other side says: File anyway. The government has signaled for years that crypto will be included. When they change the rules, they won’t give you a pass for past years. If you’ve held $15,000 in crypto on Binance since 2022 and you didn’t file, you could owe penalties for 2022, 2023, 2024, and 2025 - all at once.

Most serious crypto tax advisors, especially those who’ve seen clients get hit with penalties, recommend filing. It’s not about being overly cautious. It’s about avoiding a nightmare scenario where you’re hit with $50,000 in penalties because you assumed the rules wouldn’t change - and they did.

How to File an FBAR

You file electronically through the BSA E-Filing System. It’s free. You don’t file it with your tax return. You file it separately with FinCEN.

You’ll need:

• Full legal name and SSN or ITIN
• Foreign exchange name and address (e.g., Binance.com, registered in Malta)
• Account number or identifier (if the exchange provides one)
• Maximum value of each account in USD during the year
• Whether you have signature authority or financial interest

Most crypto exchanges don’t give you an account number like a bank does. That’s okay. You can write "Crypto Wallet ID: [your email or username]" and note that it’s a virtual currency account. Be specific. Document everything.

Deadline: April 15, with an automatic extension to October 15. No request needed. Just file by October 15, 2026, for 2025.

What to Do Right Now

If you’re holding crypto on a foreign exchange and your total balance ever hit $10,000 in 2025:

1. Log every foreign account you have access to - even if you haven’t touched it in a year.
2. Find the highest USD value of each account during 2025. Use a tax tool or manual records.
3. Add them all up. If the total is $10,000 or more, you need to file.
4. If you have fiat in any of those accounts, you definitely need to file.
5. If you’re unsure, file anyway. It’s better to file and not need to than to not file and get hit with a penalty.
6. Keep records of your valuations for at least six years.

Don’t wait for a letter from the IRS. Don’t hope the rules change in your favor. The safest move is to act now.

What’s Coming Next?

The writing is on the wall. FinCEN is moving fast to bring crypto under the same rules as traditional banking. The Infrastructure Investment and Jobs Act already requires crypto brokers to report transactions to the IRS. The next step? FBAR reporting for crypto.

Experts expect new rules to be finalized in 2026. When that happens, they’ll likely require you to report back to 2023 or 2024. If you didn’t file then, you’ll be exposed.

Right now, you have a window. It’s small. It’s closing. Use it.

Bottom Line

Crypto isn’t a legal gray area. The rules are clear: if you control foreign financial accounts and they hit $10,000, you report them. Right now, pure crypto accounts are exempt - but that exemption is temporary. The government is coming. The penalties are real. And the cost of waiting could be far higher than the cost of filing.

File. Document. Stay ahead. Don’t gamble with your money, your future, or your freedom.