Why it matters

The U.S. taxes its citizens on worldwide income regardless of where they live — and it requires disclosure of foreign financial accounts regardless of whether those accounts generate taxable income. As a Digital Nomad Visa holder in Spain, you will open a Spanish bank account, potentially receive income into it, and possibly accumulate savings in it. All of that is potentially reportable on an FBAR.

The penalties for non-compliance are severe enough that this is not a filing to discover after the fact. Build FBAR compliance into your financial planning from day one of your move to Spain.

Who must file

Any "U.S. person" — U.S. citizens, permanent residents (green card holders), and certain U.S. residents — who has a financial interest in, or signature authority over, foreign financial accounts with an aggregate value exceeding $10,000 at any point during the calendar year. "Financial accounts" include bank accounts, brokerage accounts, mutual funds, and certain other financial instruments held at foreign institutions.

What counts as a foreign financial account

  • Your Spanish bank account (BBVA, Santander, CaixaBank, etc.)
  • Spanish savings accounts or deposit accounts
  • Foreign brokerage or investment accounts
  • Fintech accounts held at EU-licensed institutions (Wise, Revolut, N26 depending on structure)
  • Any account at a non-U.S. financial institution where you have signature authority or a financial interest

Filing details

  • Form: FinCEN Form 114 (not filed with the IRS — filed separately through the BSA e-filing system at bsaefiling.fincen.treas.gov)
  • Due date: April 15, with an automatic extension to October 15 — no form required to get the extension
  • Filing period: Covers the prior calendar year (filed in 2026 for accounts held in 2025)
  • No tax due: The FBAR is a disclosure form — no tax is assessed or paid with it. It simply reports the existence and maximum balance of foreign accounts.

FBAR vs. FATCA Form 8938

These are two separate requirements that often overlap. Key differences:

  • FBAR: Filed with FinCEN, $10,000 threshold (aggregate), covers all foreign financial accounts
  • Form 8938 (FATCA): Filed with the IRS as part of your federal tax return, higher thresholds ($50,000 for single filers living in the U.S.; $200,000 for single filers living abroad), covers foreign financial assets

Many Americans living in Spain must file both. Your U.S. tax preparer (a CPA or Enrolled Agent who handles expat returns) coordinates both filings as part of your annual return.

Common mistakes

  • Missing the filing because "nothing happened" in the account. The FBAR threshold is based on the account balance, not whether you received income. A dormant Spanish savings account with €15,000 sitting in it triggers the filing obligation.
  • Not including fintech accounts. Wise, Revolut, and similar services may hold funds at EU-licensed banks — those accounts count.
  • Filing late without understanding the extension. The October 15 extension is automatic — you do not need to request it. But past October 15, penalties apply.
  • Handling FBAR separately from your annual return. Your U.S. tax preparer should handle FBAR and Form 8938 simultaneously with your 1040. Do not try to file them independently.

In total. If the aggregate balance of all your foreign financial accounts exceeds $10,000 at any point during the calendar year, you must file an FBAR reporting all foreign accounts — even individual accounts that never exceeded $10,000 themselves. The trigger is the aggregate; the reporting requirement covers everything.

Significant. Non-willful violations carry penalties of up to $10,000 per violation. Willful violations carry penalties of up to the greater of $100,000 or 50% of the account balance per violation. Criminal penalties are also possible for willful violations. This is not a form to miss or file late casually.

No — they are separate requirements with different filing authorities, forms, and thresholds. FBAR (FinCEN Form 114) is filed with FinCEN (Financial Crimes Enforcement Network) through the BSA e-filing system. FATCA (Foreign Account Tax Compliance Act) requires filing Form 8938 with the IRS — higher thresholds ($50,000–$200,000 depending on filing status and residence). Many Americans in Spain must file both.

Potentially yes, depending on how the account is structured and where the funds are held. Wise's European accounts (held in EU banking licenses) are foreign financial accounts for FBAR purposes. Revolut similarly. The key question is: do these accounts hold funds at a non-U.S. financial institution? If yes, they count toward the aggregate. Confirm with your U.S. tax preparer.