Foreign pensions generate more professional disagreement than almost any FBAR topic, because the answer genuinely depends on plan structure, and the two main reporting regimes — the FBAR and Form 8938 — treat them differently. This page gives you the framework practitioners actually use, worked through the pension types expats hold most.
The framework: is the pension an "account"?
The FBAR reaches financial accounts. So the question is whether your pension creates one:
- Defined-contribution plans with a pot — a UK workplace pension invested at a provider, a German betriebliche Altersvorsorge with a fund custodian, an Australian superannuation balance, a Canadian RRSP — hold identifiable assets for you at a financial institution. The mainstream practitioner view: reportable financial accounts.
- Pure defined-benefit promises — a final-salary scheme where you hold only a contractual promise of future payments, with no segregated pot — are commonly treated as not accounts, because there is nothing you own at an institution.
- Government social security anywhere — not reportable. Social insurance is not a financial account under either regime.
The honest caveat: neither the IRS nor FinCEN has published a definitive pension-specific rule, and practitioner positions vary by country and plan documents. The conservative end of the profession reports broadly; the aggressive end relies on the defined-benefit distinction. Middle ground: report anything with a pot, document why you did or didn't.
Country walk-throughs
United Kingdom. Workplace defined-contribution pensions (with providers like Aviva, Scottish Widows, Nest): commonly reported. Final-salary schemes: commonly not reported as accounts — but they do appear on Form 8938 as specified assets when thresholds are met. SIPPs (self-invested personal pensions): reported — they are brokerage-like accounts.
Germany. Company pensions held through a Versorgungseinrichtung or fund custodian (Pensionskasse, Pensionsfonds, fund-based Direktversicherung): commonly reported. Claims against an employer under a Direktzusage (unfunded employer promise): commonly not treated as an account. Riester and Rürup accounts with deposit balances: reported.
Canada. RRSPs and TFSAs: unambiguously reportable accounts (RRSPs also carry the famous US tax-deferral treaty election on Form 8891's successor — Form 8891 was eliminated in 2014; the deferral now flows through treaty-based return positions). CPP/QPP: not reportable.
Australia. Superannuation balances: the majority practitioner position treats super as a reportable account (and it is a Form 8938 specified asset). The ATO relationship doesn't change the US answer.
Netherlands, Japan, and others. Same framework: pot at an institution → report; pure promise or state scheme → generally not.
The Form 8938 overlay
FATCA's Form 8938 is broader than the FBAR here: foreign pensions generally count as specified foreign financial assets — including arrangements that may not be FBAR accounts — once you cross the thresholds ($200,000/$300,000 single or $400,000/$600,000 joint for those living abroad). The practical consequence surprises people: you may reasonably conclude your final-salary UK pension is not an FBAR account and still owe a Form 8938 line for it. Reporting a pension on 8938 is not an admission that it was FBAR-reportable.
The tax side (why pensions attract attention)
FBAR reporting is the paperwork layer; pensions also raise US income-tax questions — whether contributions were deductible, whether investment growth inside the plan is currently taxable or tax-deferred under a treaty, and how distributions are taxed. That analysis is country-specific and treaty-dependent, and it is the single most common reason expats with pensions end up needing professional help. The reporting guides on this site cover the paperwork; the taxation of your specific plan is a professional question.
Practical playbook
- Inventory your plans — provider, country, defined-contribution or defined-benefit, whether you receive statements showing a balance.
- Apply the pot test. Pot at an institution → FBAR-reportable in the mainstream view. Promise or state scheme → likely not; document the reasoning either way.
- Check the aggregation threshold — pension accounts count toward the $10,000 test.
- Handle Form 8938 separately — broader coverage, different thresholds; a pension can be 8938-reportable while not an FBAR account.
- Keep the paperwork — annual statements go in your record-keeping file; for past years where you now conclude reporting was required, the late-filing guide covers the catch-up, and reasonable cause documentation matters given how unsettled this area is.
This page is general information, not tax or legal advice. Pension treatment is fact- and country-specific and partly unsettled; a cross-border professional should review significant plans. See the IRS FBAR reference.
Frequently asked questions
Do foreign pensions need to be reported on an FBAR?
It depends on the plan's structure. A pension held as a financial account — with a balance you can identify, at an institution — is generally FBAR-reportable. Pure defined-benefit promises that never hold segregated funds for you are commonly not treated as accounts. This is one of the genuinely unsettled areas of foreign-account reporting.
Is a UK workplace pension FBAR-reportable?
A UK defined-contribution workplace pension (with a pot invested at a provider) is commonly treated as a reportable financial account. A pure defined-benefit final-salary scheme, where you have only a promise of future payments, is commonly treated as not an account. Practitioners diverge on edge cases.
What about Form 8938 for foreign pensions?
Form 8938's reach is broader: foreign pensions generally count as specified foreign financial assets when the thresholds are met, including arrangements that may not be FBAR accounts. Many expats therefore report a pension on Form 8938 even while reasonably concluding it is not an FBAR account.
Are social security payments from a foreign country reportable?
No. Government social insurance (contributions to, or benefits from, a national social security system) is not a financial account. Neither the FBAR nor Form 8938 requires reporting a foreign social-security entitlement.
What value do I report for a foreign pension on the FBAR?
If the pension is reportable, report the maximum account value during the year in US dollars — the current value of your pot for defined-contribution plans. For plans without accessible statements, the provider's annual statement is the documentation your record-keeping file needs.