Most Indian accounts held by a U.S. person belong on the FBAR: NRE and NRO savings accounts, every fixed and recurring deposit, FCNR(B) and RFC deposits, demat and broker accounts, mutual fund folios, and LIC or ULIP policies with a surrender value. Bank lockers, physical gold, land and flats, and shares held as paper certificates do not. A handful, led by EPF, NPS, digital wallets and crypto exchange accounts, sit in a gray zone where the rules have not been settled.

The 2025 FBAR (FinCEN Form 114) is due on Thursday, October 15, 2026, the end of FinCEN’s automatic extension. It is filed online with FinCEN through the BSA E-Filing System, not with your tax return, and a Form 4868 tax extension does not extend it. Our FBAR deadlines guide covers the calendar; this checklist covers what goes on the form. H-1B and H-4 holders should start with our FBAR guide for H-1B holders with NRE and NRO accounts, which covers who counts as a U.S. person for 2025.
You must file if you were a U.S. person in 2025 (a citizen, a green card holder, or a resident alien under the substantial presence test, which catches most H-1B and L-1 workers) and the combined maximum value of all your foreign financial accounts went above $10,000 at any point in 2025. At the official Dec 31, 2025 Treasury rate of 89.854 rupees per dollar, that is Rs 8,98,540. Once you are over the line, every account goes on the form, including the ones holding a few thousand rupees. Not sure you were a resident? Run the substantial presence test calculator first.
Free toolSubstantial Presence Test CalculatorEvery answer below rests on one regulation, 31 CFR 1010.350. It asks two questions. Is the thing a “bank account” (a savings, demand, checking or other account with a person in the business of banking), a “securities account” (an account with a person that buys, sells, holds or trades securities), or an “other financial account” (an account with a financial agency that accepts deposits, an insurance or annuity policy with a cash value, or shares in a publicly available mutual fund with a regular NAV and regular redemptions)? And do you have a financial interest in it (your name is on it as owner of record) or signature authority over it (you can move the money by instructing the bank)? If both answers are yes, you report it.
The IRS examiner manual, IRM 4.26.16, adds the negative list: directly held stocks and bonds, real estate, safe deposit boxes and precious metals are not financial accounts. Where neither source names an Indian product, we say so. Over-reporting carries no penalty; leaving off a required account can.
The FBAR is an information report, not a tax, so each item ends with its separate U.S. tax angle: “tax-free in India” does not mean tax-free for a U.S. resident. If you have missed past years, see our guide on missed FBARs for Indian bank accounts.
Start with the one-line summary, then use the detailed checklist to find the maximum value for each account.
| Account or asset | On the FBAR? | Why, in one line |
|---|---|---|
| NRE savings | Yes | Bank account you own |
| NRO savings | Yes | Bank account you own |
| NRE / NRO fixed deposits | Yes | Time deposits; each FD number is its own account |
| Recurring deposits | Yes | Deposit account with a bank or post office |
| FCNR(B) deposits | Yes | Foreign-currency time deposit in India |
| RFC account | Yes | Foreign-currency bank account in India |
| Sweep-in / auto-sweep | Yes | Savings account plus any separately numbered sweep FDs |
| Accounts closed during 2025 | Yes | Open at any time in the calendar year |
| Demat account (NSDL / CDSL) | Yes | Securities account |
| Broker trading account | Yes | Securities account, ledger cash included |
| Mutual fund folios (CAMS / KFintech) | Yes | Publicly offered fund with daily NAV |
| Sovereign Gold Bonds | Unsettled | Demat SGBs count inside the demat; RBI-ledger SGBs unclear |
| LIC endowment / ULIP | Yes | Insurance policy with a cash value |
| Term insurance | No | No cash value |
| Physical share certificates | No | Securities held directly, not in an account |
| PPF (bank or post office) | Yes | Deposit-type account in your name |
| EPF / EPFO | Unsettled | Practitioners split; report to be safe |
| NPS | Unsettled | Not named in the rules; report to be safe |
| Post office SCSS, MIS, TD, RD, savings | Yes | Deposit accounts in your name |
| NSC and KVP | Unsettled | Certificates, not clearly accounts; report to be safe |
| Joint with parent, you first holder | Yes | Owner of record; report full value |
| Joint with parent, you second holder | Yes | Still an owner of record, any operating mode |
| Parent’s account, you signatory only | Yes | Signature authority |
| Account where you hold a POA | Depends | Yes if the POA lets you move money |
| Account where you are only nominee | No | No ownership or control while the holder is alive |
| Minor child’s account you operate | Yes | Child’s own FBAR; parent reports signature authority to be safe |
| Indian credit cards | No | A credit line, not an account holding your money |
| Paytm-type wallets, UPI | Unsettled | No official guidance; UPI is not an account |
| Crypto on Indian exchanges | Unsettled | Crypto alone not reportable now; rupee balances unclear |
| Bank lockers | No | Safe deposit box is not an account |
| Physical gold and jewelry | No | Precious metals held directly |
| Land, flats, houses | No | Real estate held directly |
Bank deposits: NRE, NRO, FDs, FCNR and RFC
Step 1: find each account’s highest 2025 balance in rupees. Step 2: divide by 89.854, the Treasury Reporting Rate for India on Dec 31, 2025. Step 3: round each result UP to the next whole dollar. Step 4: add them. If the total is over $10,000, report every account. Example: NRE savings peak Rs 6,20,000 = $6,901; NRO peak Rs 1,85,000 = $2,059; one FD at Rs 5,00,000 = $5,565; a mutual fund folio peak Rs 2,30,000 = $2,560. No single account tops $10,000, but the total is $17,085, so all four go on the form. The peaks do not have to fall on the same day. Use the one year-end rate for every account, not the rate on the day of each peak. Rates: Treasury Reporting Rates of Exchange.
Investments and insurance: demat, brokers, mutual funds, SGBs, LIC
Listing the stocks or mutual fund schemes instead of the account. The FBAR wants one line per account (the demat, the trading account, each folio), with that account’s maximum value. It does not want one line per share or scheme.
Retirement and small savings: PPF, EPF, NPS and post office schemes
If EPFO or a post office cannot give you a 2025 balance before October 15, the FBAR instructions let a filer with fewer than 25 accounts list the account and tick item 15a, “amount unknown.” That is better than leaving the account off. Keep trying to get the figure for your records.
Joint accounts, POAs, nominees and signature authority
IRM 4.26.16 states that tax-law family attribution rules do not apply to the FBAR. A parent’s account in the parent’s sole name, where you have no signing power, is not yours to report, however much of it you expect to inherit.
Cards, wallets and crypto
Not financial accounts: lockers, gold, property
Before you file: records and the bigger picture
For every account, the form asks for the institution’s name and address, the account number, the account type (bank, securities or other) and the maximum value. Keep those records, and the statements behind each maximum, for five years from the FBAR due date. If your total of foreign assets is large, Form 8938 may also be due with your extended return on the same October 15 date, and it covers some items the FBAR skips, such as directly held securities. Our FBAR vs FATCA comparison lays the two side by side.
Married couples whose reportable accounts are all jointly held can file one FBAR together if both sign Form 114a and keep it on file. Otherwise, each spouse files and each reports the full value of every joint account. For the definitions behind each of these terms, see FBAR definitions: financial accounts, interests and rules.
The penalties are why the cautious calls above lean toward reporting. A non-willful failure can cost up to $16,536 per FBAR under the current penalty table, and willful violations can reach the greater of $165,353 or 50 percent of the balance, with criminal penalties possible. Listing an account that turns out not to be required costs nothing. Where an item is marked unsettled and the balance is large, have a preparer who handles Indian accounts look at it before October 15.
Frequently Asked Questions
Do I need to report my NRE account on the FBAR?
Yes. An NRE savings account is a bank account you own, so it counts under 31 CFR 1010.350 if your foreign accounts together topped $10,000 at any time in 2025. Report its highest 2025 balance converted at 89.854 rupees per dollar. NRE interest is also taxable in the U.S. even though India exempts it.
Does each fixed deposit go on the FBAR separately?
Yes. Indian banks give each fixed deposit its own number, and the FBAR instructions say each account is valued separately. List every NRE or NRO FD as its own entry with its highest 2025 value, including FDs that matured or were broken during 2025.
Is EPF reportable on the FBAR?
It is unsettled. No FinCEN or IRS guidance names EPF. Some argue it is a foreign social security-type benefit, which the IRS chart says is not reported; most practitioners treat it as a reportable account. The cautious approach is to list each EPF member ID with its highest 2025 passbook balance.
Do I report a joint account with my parents on the FBAR if I am the second holder?
Yes. Every U.S. person in whose name the account is maintained has a financial interest, whether first or second holder, and the IRM says joint accounts are not prorated. Report the full balance in Part III, naming your parent as the principal joint owner.
Are Indian mutual funds reported on the FBAR?
Yes. The rule covers publicly offered mutual funds with a regular NAV and regular redemptions. Each folio held directly with an AMC through CAMS or KFintech is a separate account. Use the highest folio value from your 2025 CAS. Indian mutual funds are also PFICs for U.S. tax purposes.
Do bank lockers, gold or Indian property go on the FBAR?
No. IRM 4.26.16 says a safety deposit box, precious metals held directly and real estate are not financial accounts, and the IRS comparison chart agrees. The bank account receiving rent or sale proceeds from Indian property is reportable, and property gains remain U.S. taxable.
Is crypto on WazirX or CoinDCX reportable on the FBAR?
Not for crypto alone, for now. FinCEN Notice 2020-2 says a foreign account holding only virtual currency is not reportable unless it holds other reportable assets, and FinCEN intends to propose changing that. An exchange account that also held a rupee balance is a gray area, so report it to be safe.
What exchange rate do I use to convert rupees for the 2025 FBAR?
Use the Treasury Reporting Rate for India on Dec 31, 2025: 89.854 rupees per dollar. Divide each account’s highest 2025 rupee balance by 89.854 and round up to the next whole dollar. The $10,000 threshold equals Rs 8,98,540. The 2025 FBAR is due October 15, 2026.