Do You Report a UK Pension on the FBAR?
Most UK pensions belong on the FBAR, because the US retirement plan exemption covers only US plans and IRAs. Here is how SIPPs, workplace pots, final salary schemes and the State Pension are treated, how to value them, and where Form 8938 fits in.
Pension statements arrive once a year, and the highest value each scheme reached is the figure that matters when you list it on the FBAR.
Written by the US UK Tax Experts team, cross-border tax specialists
UK pension on the FBAR: an introduction
In most cases, you do report a UK pension on the FBAR if your foreign accounts together pass $10,000 at any time in the year. The FBAR exemption for retirement plans covers US plans and IRAs only, not UK schemes. SIPPs and workplace pension pots are the clear cases. Final salary schemes are contested, and the UK State Pension is not reported at all.
This article sets out how each type of pension is treated and how to value it. For the wider rules, read our guide to FBAR and FATCA reporting. For the income tax side of your pension, such as contributions, growth and lump sums, see our pensions service.
Why a UK pension on the FBAR is easy to miss
Most Americans in the UK think of a pension as savings they cannot touch. Therefore, it rarely feels like a bank account. Furthermore, UK providers do not send US-style tax forms, and the pension may sit with an old employer. However, the FBAR asks about financial interests in foreign accounts, not about access. In our experience, a forgotten workplace pot is one of the most common omissions on an otherwise careful FBAR.
Why does the US retirement plan exemption not cover UK pensions?
The FBAR exemption is written for plans described in the US tax code, so a UK registered pension scheme does not qualify. The IRS says plainly that the exception is for US plans only.
What the regulation exempts
The FBAR rule is 31 CFR 1010.350. Its exceptions cover participants and beneficiaries in plans under sections 401(a), 403(a) and 403(b) of the Internal Revenue Code. They also cover owners and beneficiaries of IRAs under section 408 and Roth IRAs under section 408A. Those people do not report foreign accounts held by or for the plan. Consequently, a US 401(k) that invests through a foreign fund stays off your FBAR.
The IRS says the exception is for US plans only
The IRS manual on the FBAR, IRM 4.26.16, states that the retirement plan exception is for US plans only. It adds that foreign plans, such as a Canadian RRSP, are normally reportable. A UK pension is not a 401(a) plan or an IRA. Therefore, the exemption does not reach it, however the pension is taxed in the UK.
What the treaty does and does not do
The US-UK income tax treaty deals with how pensions are taxed. The treaty texts are on the IRS UK tax treaty documents page. The treaty can protect growth inside a UK scheme from US tax. However, it does not change the FBAR rules, which come from the Bank Secrecy Act. Our guide to the US-UK double taxation treaty covers the tax side.
Which UK pensions go on the FBAR?
SIPPs, personal pensions and workplace defined contribution pots should be reported. Defined benefit schemes are where practitioners disagree, and the UK State Pension is not an account.
SIPPs and personal pensions
A SIPP is a self-invested personal pension: an account in your name with a UK provider, holding investments you choose. It is the clearest case of a UK pension on the FBAR. Similarly, a personal or stakeholder pension is an individual account with a pot you can value. We report both. The GOV.UK guide to pension types explains that personal pensions are usually defined contribution.
Workplace defined contribution schemes
A defined contribution scheme is a pension where your pot depends on what is paid in and how the investments perform. Many workplace schemes work this way, including auto-enrolment schemes and group personal pensions. Some are run through an employer trust, which leads some advisers to argue there is no account in your name. However, you have an identified pot with a value you can look up. The cautious approach is to report it, and that is what we do.
Defined benefit schemes: the contested case
A defined benefit scheme is a pension that promises an income based on your salary and years of service. These are often called final salary or career average schemes. There is no pot in your name, only a promise backed by a pooled fund. One view is that there is no account to report. The other is that the FBAR rules carve out only US plans, so a foreign pension should be listed. Neither FinCEN nor the IRS has published guidance that settles the point.
Many careful preparers therefore disclose a defined benefit scheme on the FBAR as well. Others report it on Form 8938 only. Either position can be defended if it is deliberate, consistent each year and recorded on file. What cannot be defended is leaving every pension off because the UK treats them as tax-favoured.
The UK State Pension
The UK State Pension is not reported. It is a government entitlement built from your National Insurance record, as the GOV.UK State Pension guide explains. The IRS comparison of Form 8938 and FBAR requirements lists foreign social security type benefits as reportable on neither form. However, the payments are still income for your US return.
How do you value a UK pension on the FBAR?
You report the maximum value of each account during the calendar year, converted into US dollars. For a pension, the annual statement or the provider's online valuation is usually the starting point.
Maximum value and periodic statements
FinCEN's FBAR filing instructions define maximum value as a reasonable approximation of the greatest value during the year. You may rely on periodic statements if they fairly reflect that value. However, UK pension statements are often dated in April or on a scheme anniversary. Therefore, we look at the closing value and any online valuations during the year, and use the higher figure.
Converting to dollars
The instructions say to convert using the Treasury exchange rate for the last day of the calendar year. You use that one rate even if the highest balance came in spring. Additionally, each account is valued separately before you add them up. Our article on the FBAR exchange rate explains where to find the rate.
When you cannot find a value
The FBAR instructions include an "amount unknown" box for an account whose value cannot be determined. For a defined benefit scheme, many preparers instead use the most recent cash equivalent transfer value. A cash equivalent transfer value is the sum the scheme would pay to move your benefits elsewhere. It is an estimate, so we note on file how the figure was reached.
Does a UK pension go on Form 8938 too?
Yes, if you pass the Form 8938 threshold and must file a tax return. The IRS instructions treat an interest in a foreign pension plan as reportable, and they say how to value it.
Pensions on Form 8938
The Form 8938 instructions tell you to report your interest in a foreign pension plan or deferred compensation plan in Part VI. You do not list the plan's underlying investments separately. Unlike the FBAR, this covers defined benefit schemes clearly. Our article on FBAR vs Form 8938 compares the two forms in full.
Thresholds for people living abroad
The IRS page on whether you need Form 8938 sets the thresholds. For a single filer living abroad, you file above $200,000 on the last day of the tax year or $300,000 at any time. For a joint return, the figures are $400,000 and $600,000. Moreover, if you do not have to file a tax return, you do not file Form 8938.
Valuing a pension for Form 8938
The instructions use the fair market value of your beneficial interest in the plan on the last day of the tax year. If you do not know that value from readily accessible information, you use the value of distributions received in the year. If there were no distributions and no known value, the value is zero. However, the pension is still listed on the form.
The State Pension and Form 8938
The Form 8938 instructions say that the foreign equivalent of US social security is not reportable. They also say this does not include an interest in a foreign pension plan. Therefore, your State Pension stays off Form 8938, while your workplace and personal pensions go on it.
What happens if you left a UK pension off the FBAR?
An FBAR that omits a reportable account is incomplete, and penalties can apply. The safest fix for missed years is usually the Streamlined procedures, not a late FBAR on its own.
The FBAR deadline
The IRS FBAR page says the report is due on 15 April after the calendar year. You get an automatic extension to 15 October without asking. The FBAR is filed online through FinCEN's BSA E-Filing System, as the FinCEN FBAR page explains. It is never sent with your tax return.
The penalties
Under 31 CFR 1010.821, the non-wilful maximum is $16,536 for penalties assessed on or after 17 January 2025. The figure is adjusted for inflation, so check the current table. In Bittner v. United States, the Supreme Court held that the non-wilful penalty applies per report, not per account. Wilful penalties are far higher under 31 USC 5321. Our article on FBAR penalties covers the detail.
Catching up safely
The IRS removed its Delinquent FBAR Submission Procedures page in July 2026. Therefore, a late FBAR on its own is no longer a published penalty-free route. For most people who missed a UK pension on the FBAR through a genuine mistake, the Streamlined procedures are the safer path. Read our guide to IRS Streamlined filing and our article on missed FBAR filings.
Amending a filed FBAR
If you filed an FBAR but left out a pension, the fix depends on the reason. A simple omission in an otherwise compliant year can often be corrected with an amended report. However, if the pension also brings unreported income or missed Form 8938s, a wider catch-up may be needed. We look at all the years together before choosing a route.
A worked example of a UK pension on the FBAR
Consider a typical case. Daniel is 52, a US citizen living in Manchester, and he files as a single person. He has a UK current account, a SIPP, a pot in his current employer's defined contribution scheme and a deferred final salary pension from an earlier job. He will also receive the UK State Pension in later life. This is an illustrative example, not a real client.
His current account alone peaks above $10,000 in dollar terms, so he files an FBAR. He lists the current account, the SIPP and the workplace pot, using the highest values from his statements and online valuations. He also lists the final salary scheme, using the latest transfer value he requested. The State Pension does not appear. On Form 8938, his total stays under $200,000 at year end and $300,000 at any time, so he does not file it this year.
What Daniel's case shows
Daniel reports every UK pension on the FBAR except the State Pension. Including the final salary scheme is the cautious choice, and his file records how the value was reached. Furthermore, if his pots grow past the Form 8938 threshold, all three pensions go on that form too. Meanwhile, the tax on his pension income is a separate question for his returns.
How US UK Tax Experts can help
US UK Tax Experts prepares your FBAR and Form 8938 alongside your US and UK returns, from one file. We list every pension, including old workplace pots, and record how each value was reached. The GOV.UK pension tracing service can help you find contact details for a lost scheme. If you have missed a UK pension on the FBAR in past years, we prepare the catch-up through the right route. Our FBAR and FATCA service explains what we prepare each year.
Conclusion
The US retirement plan exemption does not cover UK schemes. Therefore, a UK pension on the FBAR is the normal position for SIPPs, personal pensions and workplace defined contribution pots. Final salary schemes are contested, and many preparers disclose them to be safe. The State Pension is not reported on either form. Value each pension consistently, convert it at the year-end rate and keep a note of your method.
Contact us
If you are unsure how to report a UK pension on the FBAR, email hello@usuktaxexperts.com or use our contact form. Tell us which pensions you hold and which years you have filed. We reply within one working day.
Frequently asked questions
In most cases, yes. The FBAR exemption for retirement plans covers only US plans and IRAs, so it does not reach UK schemes. SIPPs, personal pensions and workplace defined contribution pots should be reported once your foreign accounts pass $10,000 in total.
No. The State Pension is a government social security type benefit, not an account. The IRS lists foreign social security type benefits as reportable on neither the FBAR nor Form 8938, although the payments are still income for your US return.
Practice is divided. A defined benefit scheme has no pot in your name, so some preparers leave it off the FBAR and report it on Form 8938 only. The cautious approach is to disclose it, using a recent transfer value, and to record your method on file.
Use a reasonable approximation of the highest value during the calendar year, usually from statements and online valuations. Convert it at the Treasury exchange rate for the last day of the year. For a defined benefit scheme, many preparers use the latest cash equivalent transfer value.
Yes, if you pass the Form 8938 threshold and must file a tax return. The instructions say to report your interest in a foreign pension plan in Part VI. For a single filer living abroad, the threshold is $200,000 at year end or $300,000 at any time.
Penalties can apply to an incomplete FBAR, so it is worth fixing. Since the IRS removed its Delinquent FBAR Submission Procedures page in July 2026, a late FBAR alone is no published penalty-free route. For genuine mistakes, the Streamlined procedures are usually the safer path.
