Do not limit your FBAR to checking and ISA accounts: include UK pensions that are individual financial accounts or pension pots, exclude the State Pension, and treat a no-account final-salary scheme as the one gray area.
“I am a UK citizen and current US resident filing an FBAR. Do I need to report my UK pension plans from before I moved to the US, or do I only need to report my checking and ISA accounts?”
Summary
You do not automatically report everything called a pension: the key is whether it is an account. Most personal pensions, SIPPs, and defined-contribution pots can be handled with the same statements you use for your ISA, while the form has an “amount unknown” option for an account whose value cannot be determined.
Your answer depends on whether each pension is an actual financial account or only a promise of future benefits—not on when you opened or earned it.
Report your UK checking account. Report a Cash ISA as a bank account and a Stocks and Shares ISA as a securities account because both are foreign financial accounts maintained by a UK institution; the ISA’s UK tax-free label does not create an FBAR exemption (31 CFR 1010.350(c)(1)–(2); IRS Publication 5569, p. 2).
Include a personal pension, SIPP, or defined-contribution workplace pension when the provider maintains an identifiable member account with a balance or cash value for you. Foreign retirement accounts are not automatically covered by the U.S.-qualified-plan exception, and IRS Publication 5569 expressly treats several non-U.S. retirement accounts as FBAR-reportable (31 CFR 1010.350(g)(4); IRS Publication 5569, pp. 2, 6).
Official FBAR material does not squarely decide a defined-benefit promise with no member-owned account or cash value, and practitioners disagree. The conservative filing route is to include the provider and plan/member designation; FinCEN Form 114 Item 15a permits “amount unknown” when an account value cannot be determined. If the scheme does provide an individual account and value, use the pension-pot branch instead (FinCEN Form 114 Instructions, Items 15a and 18).
Do not list the State Pension entitlement itself: GOV.UK describes it as a benefit based on your National Insurance record, not a bank, securities, or other financial account. The FBAR regulation reaches foreign financial accounts, not a bare government-benefit entitlement (31 CFR 1010.350(a), (c); GOV.UK New State Pension guidance).
Apply these branches only for a calendar year in which you are a U.S. person for FBAR purposes and the combined-account threshold is exceeded.
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Next steps
These steps identify every reportable UK account, calculate the filing threshold, and complete the FBAR correctly.
Start with the reported calendar year
Sort each UK item by account type
List every UK account you owned or controlled during the year. Classify checking and Cash ISAs as Bank, Stocks and Shares ISAs as Securities, and an account-based pension under the category matching its structure; choose Other and briefly describe it if neither Bank nor Securities fits. Do not list the State Pension entitlement itself.
Requirements
Value accounts separately
Calculate each annual maximum
For each account, use a reasonable approximation of its highest calendar-year value; periodic statements are acceptable if they fairly show the maximum. Convert that GBP maximum using the Treasury Financial Management Service rate for December 31 of the reported year and round up to the next whole U.S. dollar.
Requirements
Before completing account entries
Apply the combined $10,000 test
Add the separate annual maxima. If the total exceeds $10,000, file an FBAR and report every reportable account, even one individually below $10,000; if the total does not exceed $10,000, no FBAR is required.
Requirements
For a 2025 FBAR: by October 15, 2026
E-file FinCEN Form 114
File electronically through FinCEN’s BSA E-Filing System at https://bsaefiling.fincen.gov/. The normal deadline is April 15 following the reporting year, but the extension to October 15 is automatic and requires no request; do not attach the FBAR to your federal income-tax return.
Requirements
After filing
Keep the supporting records
Keep the account name, number or designation, institution name and address, account type, and annual maximum-value support for five years from the FBAR due date.
Requirements
Legal sources
The answer comes from 31 CFR 1010.350, IRS Publication 5569 and current FBAR guidance, FinCEN’s Form 114 instructions, and GOV.UK State Pension guidance; the practitioner source is used only to show the defined-benefit disagreement.
31 CFR 1010.350
The controlling regulation defines reportable foreign accounts and limits the retirement-plan exception to specified U.S. tax-qualified plans and IRAs.
(a), (c), and (g)(4)
Each United States person having a financial interest in, or signature or other authority over, a bank, securities, or other financial account in a foreign country shall report such relationship to the Commissioner of Internal Revenue for each year in which such relationship exists and shall provide such information as shall be specified in a reporting form prescribed under 31 U.S.C. 5314 to be filed by such persons. Participants and beneficiaries in retirement plans under sections 401(a), 403(a) or 403(b) of the Internal Revenue Code as well as owners and beneficiaries of individual retirement accounts under section 408 of the Internal Revenue Code or Roth IRAs under section 408A of the Internal Revenue Code are not required to file an FBAR with respect to a foreign financial account held by or on behalf of the retirement plan or IRA.
IRS Publication 5569
The IRS guide identifies bank and securities accounts as reportable and confirms that foreign tax-favored retirement and savings accounts can be FBAR accounts.
pages 2 and 6
Financial accounts include: • Bank accounts such as savings and checking accounts, and time deposits, • Securities accounts, such as brokerage accounts, securities derivatives accounts, or other financial instruments accounts; Example: Canadian Registered Retirement Savings Plan (RRSP), Canadian Tax-Free Savings Account (TFSA), Mexican individual retirement accounts (Fondos para el Retiro) and Mexican Administradoras de Fondos para el Retiro (AFORE) are foreign financial accounts reportable on the FBAR.
FinCEN Form 114 / IRS FBAR guidance
This establishes the combined $10,000 filing threshold for U.S. persons with foreign accounts.
Who must file
A U.S. person, including a citizen, resident, corporation, partnership, limited liability company, trust and estate, must file an FBAR to report: a financial interest in or signature or other authority over at least one financial account located outside the United States if the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.
FinCEN Form 114 / IRS FBAR guidance
The IRS page supplies the filing deadline, automatic extension, electronic-filing rule, and five-year record period.
When and how to file; Records to keep
The FBAR is an annual report, due April 15 following the calendar year reported. You’re allowed an automatic extension to October 15 if you fail to meet the FBAR annual due date of April 15. You don’t need to request an extension to file the FBAR. You must file the FBAR electronically through FinCEN’s BSA E-Filing System. Generally, you must keep these records for five years from the due date of the FBAR.
FinCEN Reporting Maximum Account Value
FinCEN explains how to estimate each annual maximum and convert a GBP maximum to U.S. dollars.
Steps 1–2
Determine the maximum value of each account (in the currency of that account) during the calendar year being reported. The maximum value of an account is a reasonable approximation of the greatest value of currency or nonmonetary assets in the account during the calendar year. Periodic account statements may be relied on to determine the maximum value of the account, provided that the statements fairly reflect the maximum account value during the calendar year. In the case of non-United States currency, convert the maximum account value for each account into United States dollars. Convert foreign currency by using the Treasury’s Financial Management Service rate for the last day of the calendar year.
FinCEN Form 114 Line Item Instructions
The form instructions provide the account categories and permit an unknown-value entry.
Items 15a and 16
Check this box if the value of the account cannot be determined. From the dropdown list select Bank, Securities, or Other. If other is selected specify type in space provided.
GOV.UK New State Pension guidance
This identifies the UK State Pension as a National Insurance-based benefit rather than an individual investment account.
Your National Insurance record
Your new State Pension is usually based on your own National Insurance record.
Practitioner analysis
This non-government source is included only to document the disagreement over no-account defined-benefit pensions, not to establish the governing rule.
Some practitioners take the position that these plans do not need to be reported on the FBAR. We disagree.
These are the official rules as published on the cited dates; rules change.
This is general information about official processes, not legal advice, and SettleKit is not a law firm.
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