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 Minor Child Filing Requirements: What Parents Must Know

If your child has a financial interest in foreign financial accounts FBAR rules apply. You file the FBAR the same way as your own, through FinCEN Form 114. The Report of Foreign Bank and Financial Accounts covers every United States person, including minor children. No minimum age exists. A newborn with a foreign bank account in their name follows the same rules as an adult.

Many parents do not realize that FinCEN requires FBAR minor child filing just like adult filing. The $10,000 aggregate value threshold applies equally to minors. If the combined value of all foreign financial accounts held by or for a child exceeds $10,000 at any point during the calendar year, someone must file an FBAR on the child's behalf. This guide covers who handles the filing, which accounts count, and how to complete FBAR minor child filing correctly.

Does a Minor Child Need to File FBAR Reports?

Yes. Under 31 USC 5314 and the Bank Secrecy Act, every United States person who has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value exceeds $10,000 at any time during the year. The law has no age exception. A minor child who is a US person — a US citizen or resident — must file an FBAR under the same requirements as any adult.

This applies even if the child earned no income, filed no tax return, and played no role in managing the account. Specifically, FBAR reporting depends on the existence of a financial interest, not on the child's ability to control the funds. See FBAR $10,000 threshold and aggregate value.

Who Is Responsible for FBAR Minor Child Filing?

Generally, the child is responsible for their own FBAR. However, if a child cannot file for any reason — including age — the child's parent or legal guardian handles FBAR minor child filing on their behalf. The IRS states this directly in its FBAR and filing guidance. A spouse can also serve as the responsible filer if both parents agree.

The parent or guardian completes FinCEN Form 114 using the child's personal information — name, date of birth, Social Security Number or ITIN, and address. The parent signs the form as the filer. You file the child's own FBAR, not your own. Do not report the child's accounts on your own FBAR. The child's accounts appear on a separate filing.

When Does the Child File Their Own FBAR?

Generally, the child is responsible for filing an FBAR once they reach the age of majority — typically 18 in most states. No universal rule governs exactly when a minor transitions to filing independently, as age the child parent relationship and state law all determine when the shift happens. In practice, the IRS expects a parent or spouse to handle the filing for any child who cannot manage it on their own.

What the Law Says: 31 CFR 1010.350 and FBAR Minor Child Filing

The FBAR regulations under 31 CFR 1010.350 define who must file and what counts as a foreign financial account. The regulation does not mention "minor children" by name. Instead, it covers this through its treatment of persons who cannot file on their own.

Under 31 CFR 1010.350(g)(3), if a US person cannot file an FBAR — including because of age — someone else must file on their behalf. FinCEN treats minors the same way it treats incapacitated persons. A parent, guardian, or other person with legal authority must ensure the filing gets done.

A child being too young to understand financial reporting does not remove the duty. The responsibility shifts to the parent or guardian. Failure to file can trigger the same penalties that apply to adults. FinCEN assesses those penalties against the responsible party.

Which Foreign Accounts Trigger FBAR Filing for a Minor Child?

FBAR requirements for children mirror those for adults. You must report all foreign financial accounts in which the child has a financial interest in or signature authority over. The types of accounts that count include:

Account Type	Reportable?	Notes
Foreign bank accounts (savings, checking)	Yes	Accounts at any foreign bank
Custodial accounts (UTMA/UGMA) at foreign banks	Yes	Child is the beneficial owner
Foreign brokerage accounts	Yes	Stocks, bonds, mutual funds
Foreign trust accounts benefiting the child	Yes	If child has financial interest
Foreign life insurance with cash value	Yes	Whole life, endowment policies
Foreign retirement accounts (education funds)	Yes	Even if tax-advantaged abroad
US domestic accounts	No	Not reportable on the FBAR

The key factor is the location of the institution. In short, any account at a bank outside the US counts as a foreign account for FBAR purposes. The currency and type of account do not matter. For more on which accounts need FBAR reporting, see the first-time filer guide.

Custodial Accounts: UTMA and UGMA at Foreign Banks

UTMA and UGMA let adults hold assets in a custodial account for a minor. When a foreign bank holds these accounts, FBAR filing duties apply to both the child and the custodian.

The child's FBAR: The minor is the beneficial owner of a UTMA or UGMA account. Because the child has a financial interest in the account, the parent must file FBAR on the child's behalf if the aggregate value of all the child's foreign accounts exceeds $10,000 during the year.

The custodian's FBAR: The custodian — typically a parent, grandparent, spouse, or other adult — has signature authority over the account. The custodian must also report the account on their own FBAR, because they control the funds until the child reaches the age set by state law.

Example: Sarah's Education Account

Sarah is 8 years old and a US citizen. Her grandmother in Germany set up a custodial account at Deutsche Bank with a balance of EUR 15,000. Sarah's mother, Emily, is the custodian. Both Sarah (through Emily as her parent) and Emily (as custodian with signature authority over the foreign account) must file separate FBARs. Emily files the FBAR for Sarah using Sarah's information and also reports the account on her own FBAR.

Accounts Held in a Child's Name Abroad

Foreign relatives often open bank accounts in a child's name in their home country. This is common in families with ties to India, the UK, Israel, or Australia. Grandparents may deposit gifts or savings into a foreign bank account in the child's name. Even if the child has never visited the country or seen the account, you must report it.

Therefore, a US parent should keep records of all foreign accounts held in their children's names. Track the value of each account throughout the calendar year. You need the maximum value for each account, converted to US dollars using the Treasury exchange rates.

Jointly Owned Accounts

If a child's foreign account is jointly owned with a parent, spouse, or other US person, all US persons with a financial interest must report the full value of the jointly owned accounts on their own FBARs. Do not split the value. See FBAR joint account reporting rules for detailed guidance on how to report the jointly owned accounts correctly.

How to Complete FBAR Minor Child Filing Step by Step

To complete FBAR minor child filing, you must file electronically through the BSA E-Filing system at FinCEN. No paper or PDF option exists. The Financial Crimes Enforcement Network (FinCEN) requires all FBARs to go through the BSA filing system.

Steps to File

Go to the BSA E-Filing site: Visit bsaefiling.fincen.gov
Select FinCEN Form 114: Choose the FBAR filing option
Enter the child's information: Name, SSN or ITIN, date of birth, address
List each foreign account: Account number, bank name, country, type of account
Report maximum value: Highest balance during the year in USD for each account
Sign as parent or guardian: You sign on behalf of the child
Keep records: If a spouse or other person also needs to authorize the filing, complete FinCEN Form 114a and retain it for five years. You do not submit Form 114a to FinCEN — keep it with your records

The FBAR is due April 15 of the following year, with an automatic extension to October 15. You do not need to request the extension.

Or let FBAR Direct prepare your filing. We are a FinCEN-registered institution (TCC: PBSA8180). Upload your child's foreign bank statements, and we handle the currency conversion, form preparation, and filing.

What Are the Penalties for Not Filing?

Penalties for failure to file an FBAR are the same whether the filer is an adult or a minor child. FinCEN assesses penalties against the person required to file. For a minor, that means the responsible parent or guardian.

Non-willful penalties: Up to $16,117 per violation per year under 31 USC 5321(a)(5)(B)(i) (2025 inflation-adjusted). Each unreported account per year counts as one violation.

Willful penalties: The greater of $100,000 or 50% of the account balance per year under 31 USC 5321(a)(5)(C).

Criminal penalties: Fines up to $250,000 and 5 years imprisonment under 31 USC 5322.

Additionally, parents cannot claim ignorance of their child's foreign accounts as a defense. If you knew or should have known about the account, the IRS can hold you liable. For a full breakdown of penalty tiers, see FBAR penalties: what happens if you do not file.

What If You Never Filed FBAR for Your Child?

If you have not filed FBARs for your child in prior years, come into compliance before the IRS contacts you. Fortunately, the IRS offers several paths for filing late FBAR submissions and delinquent FBARs.

Delinquent FBAR Submission Procedures

If your child's foreign accounts earned no income that you should have reported on a US tax return, you may qualify for the Delinquent FBAR Submission Procedures. Under this program, the IRS may waive penalties if all income was reported and the failure to file was non-willful.

Streamlined Filing Compliance Procedures

If unreported income ties to the foreign financial assets, the Streamlined Filing Compliance Procedures apply. You file the last 3 years of amended tax returns and the last 6 years of delinquent FBARs. The domestic streamlined penalty is 5% of the highest aggregate value.

When to Seek Professional Help

Consider consulting a qualified tax professional if:

Your child's foreign accounts exceed $100,000 in aggregate value
Unreported income ties to the foreign accounts
You have not filed FBAR returns for multiple years
You hold foreign trust assets on behalf of the child
The IRS has contacted you or your spouse about foreign accounts or assets

Key Takeaways

Minor children must file an FBAR under the same rules as adults — no age exemption exists
Because generally child is responsible for filing an FBAR, a parent or legal guardian handles it when the child cannot
31 CFR 1010.350 treats minors the same as incapacitated persons for filing purposes
UTMA and UGMA custodial accounts at foreign banks require reports from both the child and the custodian
Accounts held in a child's name abroad — even if opened by foreign relatives — count toward the $10,000 threshold
Penalties for not filing apply to the responsible parent or guardian
File the FBAR electronically through the BSA E-Filing system using the child's information
Come into compliance promptly if you missed filing late FBARs or delinquent FBARs for prior years

Frequently Asked Questions

Does a minor child need to file an FBAR?

Yes. Under 31 USC 5314 and 31 CFR 1010.350, every United States person must file an FBAR if their foreign financial accounts exceed $10,000 in aggregate value during the year. Children are not exempt. If a child cannot file, a parent or guardian must file on their behalf.

Who is responsible for filing a child's FBAR?

Generally, child is responsible for their own filing. However, if a child cannot file their own FBAR for any reason, the parent or legal guardian handles it. The IRS states this in its FBAR guidance. The parent files using the child's personal information and signs as the responsible party.

Do UTMA or UGMA accounts at foreign banks require an FBAR?

Yes. Custodial accounts under UTMA or UGMA held at foreign banks count as foreign financial accounts. FBAR rules apply to both the child (as beneficial owner) and the custodian (who has signature authority over the account). Both may need to report the account on separate FBARs. The value counts toward the $10,000 aggregate threshold for each person.

What if a grandparent opened an account for my child in another country?

If a foreign relative opened a bank account in your child's name at a foreign bank, that account must appear on an FBAR. It does not matter that the child has never visited the country or accessed the funds. As long as the child has a financial interest in the account and the aggregate value of all foreign accounts exceeds $10,000, someone must file an FBAR.

Can I report my child's accounts on my own FBAR?

No. Your child's accounts must appear on a separate FBAR filed using the child's name, SSN or ITIN, and personal information. However, if you also have signature authority over or a financial interest in the same account, report it on your own FBAR as well.

At what age does a child file their own FBAR?

No fixed federal age exists. Generally, once a child reaches the age of majority — typically 18 — the child handles their own FBAR going forward. Before that age, the parent or guardian manages the filing.

What are the penalties if I do not file for my child?

FinCEN assesses penalties against the responsible party. Non-willful penalties reach $16,117 per account per year under 31 USC 5321. Willful penalties can reach $100,000 or 50% of the account balance. Parents who knew about the accounts cannot claim ignorance.

Can I file the FBAR for my child using a PDF form?

No. FinCEN requires all FBARs to go through the BSA E-Filing system electronically. No PDF or paper option exists. You file at bsaefiling.fincen.gov or through a FinCEN-registered filing service.

Let FBAR Direct Handle Your Filing

FBAR minor child filing means tracking foreign bank statements, converting values to USD using Treasury rates, and completing FinCEN Form 114. If you have multiple children with foreign accounts, each child needs a separate filing. Whether you have never filed FBAR returns before or you need to catch up on late FBAR submissions, we can help.

Let FBAR Direct prepare your filing — you review and approve before we submit to FinCEN on your behalf. Upload your statements and we handle conversion, form preparation, and filing. See how it works.

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. This article is current as of April 10, 2026.