$10,000.01
The threshold that triggers an FBAR
The FBAR threshold is $10,000.01, one cent over $10,000. FinCEN's rule requires the FBAR only when the aggregate maximum value of your foreign financial accounts exceeds $10,000 at any point during the calendar year. Reaching $10,000 is not enough.
"Aggregate maximum value" is the part that catches people. It is the sum of each account's highest balance during the year, not your combined balance today.
An NRI with $4,000 in account A and $4,000 in account B right now might think they are well under the threshold. If A peaked at $8,000 in March 2025 and B peaked at $7,000 in July 2025, the aggregate maximum for 2025 is $15,000, and the FBAR is required.
Most NRI guidance online says "$10,000 or more," which is wrong on two counts. Getting this calculation wrong on a Form 114 is a non-trivial mistake.
Two things most NRIs get wrong about this calculation
First, FinCEN does not use today's spot rate. The Form 114 instructions say to convert each account's maximum balance to USD using the Treasury Department's published exchange rate for the last day of the year.
Second, crossing the $10,000 aggregate-maximum threshold once during the year, even for one day, puts every foreign financial account you held on the FBAR. That includes the accounts under $10,000.
Take a ₹6 lakh NRE FD, a ₹3 lakh NRO savings account and ₹50,000 in your mother's joint account where you are a signatory. Together they cross the line, and all three accounts go on the form regardless of their individual sizes.
The same money can count twice
Aggregate maximum is a sum of peaks. It is not a balance you ever held, and the peaks do not have to happen on the same day.
Suppose you move ₹8 lakh from savings into a fixed deposit in June. The savings account's highest balance for the year includes that ₹8 lakh, and so does the FD's. On the form, it shows up twice.
FinCEN is aware of this. The rule is built to be simple and wide, not precise.
A joint account works the same way. Each holder reports the full balance, not half. Two spouses on one ₹10 lakh account each report ₹10 lakh.
What goes into the sum
What counts as a "foreign account" is broader than many NRIs expect. PPF, NPS, LIC policies with cash value and any account where you are a signatory all count toward your FBAR threshold. Most NRIs miss at least one. The full list is in FBAR Deadline: The Automatic Extension to October 15.
The flat you own directly, physical gold and cash stay out. They are not financial accounts. The account the rent lands in is one.
The rupee moves the line
The threshold is in dollars, and your balances are in rupees. In early May 2025, a dollar bought ₹84.67. In early May 2026, it bought ₹94.91.
The same rupee balance converts to fewer dollars every year the rupee slides. An account that put you over the line in an earlier year may not do it now, and the reverse when you add to it.
Run the number every year, and do not assume last year's answer. More on the currency in The Rupee's Quiet Slide.
Do you also need to file FATCA Form 8938?
Most NRIs do not need to file Form 8938. It is the IRS's separate FATCA disclosure form for foreign financial assets, and its thresholds are much higher than the FBAR's.
If you file single or married-filing-separately, you need it only if your specified foreign assets exceeded $50,000 on the last day of 2025 or $75,000 at any point during the year. For married-filing-jointly, those thresholds double to $100,000 / $150,000. If you live abroad, they go up further still ($200,000 / $300,000 single, $400,000 / $600,000 joint).
FATCA also covers a broader asset definition that includes foreign stock, partnership interests and certain instruments held outside an account. If your accounts are at this level, talk to a cross-border CPA, because the penalties start at $10,000 and escalate.
Two forms, not one
FBAR and FATCA are often used as if they were the same word. They are different filings.
They go to different agencies. The FBAR goes to FinCEN, on its own, online. Form 8938 goes to the IRS, attached to your 1040.
They have different thresholds. The line is $10,000 for the FBAR, whoever you are. It is $50,000 and up for Form 8938, depending on how you file and where you live.
They use different math. The FBAR adds up each account's own peak. Form 8938 looks at what everything was worth on the last day of the year, and at its highest point.
They reach different assets. Your parent's account where you only have signatory authority goes on the FBAR. It is generally not a Form 8938 asset if none of the money is yours. Shares in an Indian company held outside any account go on Form 8938 and not on the FBAR.
One does not cover the other. If your foreign accounts alone put you over the Form 8938 threshold, you are over the FBAR threshold too. File both. Many of the same accounts get listed twice.
Neither form taxes anything. They are disclosures. The interest on those accounts goes on your 1040 separately, including NRE interest that India does not tax.
Playbook Move: Do not estimate. Pull the highest 2025 balance for every account, convert each at the Treasury year-end rate, and add them up. At one cent over $10,000, every account goes on the form. Our free FBAR calculator does the conversion and the sum, and checks the Form 8938 thresholds while it's there. If you're above $50,000, spend an hour with a cross-border CPA before you file.
From Edition 1 of the NRI Playbook newsletter. For informational purposes only; not financial, tax, or legal advice. For decisions about your specific situation, consult a qualified cross-border tax professional.