FBAR Germany Bank Accounts: Reporting Bausparen, Riester-Rente, and More
Matt Cohen, CPA ·
FBAR Direct prepares and files your FBAR (FinCEN Form 114) on your behalf. You are responsible for reviewing all information for accuracy before submission to FinCEN. This article is for informational purposes only and does not constitute tax, legal, or financial advice.

FBAR Direct prepares and files your FBAR (FinCEN Form 114) on your behalf. You are responsible for reviewing all information for accuracy before submission to FinCEN. This article is for informational purposes only and does not constitute tax, legal, or financial advice.
FBAR Germany Bank Accounts: Reporting Bausparen, Riester-Rente, and More
This guide covers FBAR Germany bank accounts — which accounts you must report, how to file your FBAR FinCEN Form 114 through the BSA filing system, and what happens if you don't. For expats living in Germany, the FBAR reporting requirement applies to foreign financial assets at any time during the tax year. Even if you hold assets in a trust, entities, or life insurance policies, the FBAR you must file covers all of those accounts.
If your foreign financial accounts exceeded the threshold of $10,000 at any time during the calendar year, you must file an FBAR. The FBAR is the Report of Foreign Bank and Financial Accounts — the FBAR FinCEN form — under 31 CFR 1010.350. You file the FBAR electronically through the BSA E-Filing System — not with your federal tax return.
Any US person — US citizen, US resident, or green card holder — who has a financial interest in or signature authority over foreign financial accounts must file an FBAR when the aggregate value exceeds the threshold. Even if your spouse holds jointly owned accounts, you must report those accounts. When filing the FBAR, you must list all foreign accounts — such as bank accounts, brokerage accounts, mutual funds, trusts, entities, and savings held outside the United States. If you need help filing, a tax professional can guide you through the process.
Which FBAR Germany Bank Accounts Must You Report?
All German bank accounts held by a US person qualify as foreign financial accounts under 31 CFR 1010.350(c). The account name or purpose does not change your FBAR filing requirements — every one of these accounts is reportable. The FBAR as a foreign bank account report covers all accounts with a balance at any time during the year. Even if an account or deposit held value for a single day, you must report it on the form. The accounts that the FBAR covers include accounts brokerage accounts and other foreign accounts at German institutions.
| Account Type | German Name | FBAR Reportable? |
|---|---|---|
| Checking account | Girokonto | Yes |
| Savings account | Sparkonto | Yes |
| Overnight money | Tagesgeldkonto | Yes |
| Fixed-term deposit | Festgeldkonto | Yes |
| Building savings | Bausparvertrag | Yes |
| Riester pension | Riester-Rente | Yes |
| Employer pension | Betriebliche Altersvorsorge (bAV) | Yes (if you have financial interest) |
| Self-employed pension | Ruerup-Rente (Basisrente) | Yes |
| Securities depot | Wertpapierdepot (brokerage accounts) | Yes |
| Life insurance | Kapitallebensversicherung | Yes |
Are Sparkassen Separate Institutions?
German Sparkassen are publicly owned financial institutions. Each Sparkasse is a separate the foreign bank for FBAR reporting. If you hold accounts at Berliner Sparkasse and Hamburger Sparkasse, those are accounts at two different institutions. Report each account on your foreign bank account report (FinCEN Form 114). Even if an account had a zero balance at the time, you must still file it if the account was open. The accounts the FBAR covers include all accounts at these institutions, regardless of type.
What About N26 and Online Banks?
Digital banks like N26 are German financial institutions. An N26 account is a foreign financial account under the same rules. To file an FBAR you must include online bank accounts alongside traditional bank accounts. If you file an FBAR, you must report the N26 account just as you report the account on your tax return.
Are Bausparen Contracts Reportable on the FBAR?
Yes — a Bausparvertrag is a reportable foreign financial account. Bausparkassen — such as Schwaebisch Hall, Wuestenrot, LBS, and BHW — are financial institutions under German banking law. You must report the savings balance at any time in your Bausparvertrag on the FBAR under 31 CFR 1010.350(c).
However, if you drew the Bauspardarlehen and no savings balance remains, the loan is a liability — not a financial account. Even if the balance at the time was small, you still need to file an FBAR for that account when your total foreign bank accounts exceed the threshold.
Furthermore, the Wohnungsbauspraemie and Arbeitnehmersparzulage paid by Germany into your Bausparvertrag raise the account balance. Include those government subsidies when you calculate the maximum account value. Your spouse must also report any jointly owned Bausparvertrag on their FBAR and file separately if they choose not to file jointly.
Are Riester-Rente and Betriebliche Altersvorsorge Reportable?
Yes — Riester-Rente and Betriebliche Altersvorsorge accounts are reportable foreign financial accounts on the FBAR. To file an FBAR, you must include all retirement accounts held at foreign financial institutions. A Riester-Rente at Allianz, Deutsche Bank, or DWS is a foreign financial account because the institution is outside the United States. Report the total account balance, including Zulagen and investment gains. The tax treaty does not exempt Riester-Rente from the FBAR. See our guide on FBAR foreign pension and retirement accounts.
Betriebliche Altersvorsorge (bAV) refers to German employer pensions. Whether a bAV triggers the FBAR depends on whether you have a financial interest under 31 CFR 1010.350(e)(1):
- Direktversicherung, Pensionskasse, Pensionsfonds: Report the vested balance on your FBAR.
- Direktzusage and Unterstuetzungskasse: Unfunded book reserves — the IRS has not required FBAR reporting for unfunded promises.
Therefore, when in doubt, report the account. Over-reporting carries no penalty for non willful violations. Under-reporting can cost up to $16,117 per penalty under 31 USC 5321(a)(5)(B). Non compliance with the reporting requirement may lead to failing to file penalties. If you file an FBAR you must include all accounts that held funds at any time during the year.
How Do You Convert EUR to USD for FBAR Reporting?
The FBAR requires the maximum value of each foreign financial account during the calendar year in USD. For German accounts in EUR, find the peak balance at any time during the year. Convert it using the US Treasury Department's December 31 exchange rate from the Treasury Reporting Rates page. Do not use the ECB rate or a Google rate.
Example: Stefan in Frankfurt holds a Girokonto at Deutsche Bank (peak EUR 12,500), a Tagesgeldkonto at ING-DiBa (peak EUR 28,000), and a Bausparvertrag at Schwaebisch Hall (EUR 15,000). Using the 2025 Treasury rate of 1 EUR = $1.03, his total is $57,217. Stefan must file an FBAR for the 2025 tax year.
For details, see our guide on how to calculate maximum account value for FBAR.
Does the Germany-US Tax Treaty Affect FBAR Obligations?
The tax treaty applies to federal tax and income on your tax returns only. The FBAR the Treasury Department requires is a Bank Secrecy Act (BSA) foreign bank account report under 31 USC 5314, enforced by the Financial Crimes Enforcement Network (FinCEN). Even if you are a dual US-German citizen living in Germany who claims treaty residency, you must still file the FBAR for all foreign accounts exceeding the threshold.
Similarly, US military personnel living abroad in Germany with foreign accounts — such as bank accounts or savings accounts — are US persons under the BSA. Even if SOFA covers tax obligations, it does not cover BSA filing requirements.
Does Germany Report Your Accounts to the IRS?
Yes — German banks report your accounts to the IRS. German financial institutions send US person account data to the BZSt, which shares it with the IRS under FATCA. The accounts the IRS receives include checking, savings, accounts brokerage accounts, insurance policies, and retirement accounts. If you have not filed your FBAR, the IRS may already hold records. See our article on FBAR penalties and what happens if you don't file.
What Are the FBAR Penalties for Not Reporting Germany Bank Accounts?
The IRS can assess civil FBAR penalties for each calendar year you fail to file. You owe the FBAR if you have accounts at German banks — if you do not file, you must understand the consequences. Non-willful penalties reach up to $16,117 per violation under 31 USC 5321(a)(5)(B). The Supreme Court ruled in Bittner (2023) that non-willful penalties apply per report, not per account.
Willful violations carry the greater of $100,000 or 50% of the unreported account balance under 31 USC 5321(a)(5)(C). Criminal penalties under 31 USC 5322 can reach $250,000 and five years in prison.
If you have never filed an FBAR, three compliance paths exist:
- Streamlined Filing Compliance Procedures for non-willful filers
- Delinquent FBAR Submission Procedures for delinquent FBARs with a reasonable cause
- Voluntary Disclosure Practice for willful cases
For details, see our FBAR first-time filer guide.
How Do You File an FBAR for Your Germany Bank Accounts?
To file an FBAR you must submit FinCEN Form 114 through the BSA E-Filing System at bsaefiling.fincen.treas.gov. The FBAR deadline for the 2025 tax year is April 15, 2026, with an automatic extension to October 15, 2026 under 31 CFR 1010.306(c).
For each account, gather these details:
- Bank name (e.g., Deutsche Bank, Sparkasse)
- Account number or IBAN
- Type of account (checking, savings, pension, life insurance policies)
- Maximum account value in USD during the year
Keep copies of your German bank statements for at least six years per 31 CFR 1010.420. If your foreign financial accounts — bank accounts, brokerage accounts, and other accounts with assets and funds — total more than $50,000, you may also need to file FATCA Form 8938 with your tax returns. Now is the time to file your FBAR before the deadline for the tax year passes.
Let FBAR Direct prepare your filing — upload your German bank statements and we handle the EUR conversion, account identification, and FBAR submission to FinCEN. See how it works.
Frequently Asked Questions
Below are the most common questions about reporting German foreign financial accounts on FinCEN Form 114.
Do I need to file an FBAR for a Bausparvertrag even during the savings phase?
Yes. A Bausparvertrag is a financial account at a foreign financial institution under 31 CFR 1010.350(c). The account's purpose does not change its status. Filing an FBAR is required if your aggregate foreign accounts exceeded at any point $10,000. You must file your FBAR through the BSA filing system by the due date.
Is my Riester-Rente reportable even though it has government subsidies?
Yes. Riester-Rente accounts are foreign financial accounts for FBAR purposes. The German Zulagen do not affect your FBAR reporting. Report the total balance, including subsidies and returns.
Do US military members stationed in Germany need to file an FBAR?
Yes. US military personnel are US persons under the Bank Secrecy Act. A Girokonto at a Sparkasse near a US base counts as a foreign bank account. SOFA does not create an FBAR exemption. If your aggregate foreign financial accounts exceed $10,000 at any time during the year, you must file an FBAR.
What exchange rate do I use for German accounts held in EUR?
Use the Treasury Department's December 31 exchange rate from the Treasury Reporting Rates page. Don't use the ECB rate or a currency converter. See our guide on FBAR exchange rates and Treasury Department rates.
Does the Germany-US tax treaty exempt me from filing my FBAR?
No. The tax treaty covers income tax only. The FBAR is a Bank Secrecy Act requirement under 31 USC 5314. A US citizen in Germany must still file the FBAR for foreign accounts exceeding $10,000.
Does Germany report my account information to the IRS automatically?
Yes. Under FATCA, German financial institutions report US person account data to the BZSt, which sends it to the IRS. Filing your FBAR is not optional when the IRS already holds records of your German accounts.
Let FBAR Direct Handle Your German Account Filing
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Tax regulations change frequently. Always verify current requirements at IRS.gov or FinCEN.gov. For advice specific to your situation, consult a qualified expat tax professional. This article is current as of March 10, 2026.
The information in this article is current as of March 10, 2026. Tax regulations change frequently. Always verify current requirements at IRS.gov or FinCEN.gov. For advice specific to your situation, consult a qualified tax professional.
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