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FBAR Guard

Do I report my Bitvavo account on the FBAR?

Updated

Checked against official sources on How we check

Short answer

Not if it holds only crypto: under FinCEN Notice 2020-2, a foreign account holding only virtual currency is not reportable on the FBAR.⁠Source 1

A euro balance is the open point. The notice keeps an account reportable if it also holds other reportable assets, and no guidance says whether Bitvavo's euro balance is one.⁠Source 1⁠Source 2

Crypto alone is excluded. How to treat a euro balance held alongside it is not settled, so record it either way.

What is known and what is open

What is known
  • A foreign account holding only virtual currency is not currently reportable. An account that also holds other reportable assets is reportable under the normal rules.⁠Source 1
  • Bitvavo's terms describe Bitvavo B.V. as licensed under the EU's MiCA rules to run a crypto trading platform. This is the provider's own statement.⁠Source 2
  • According to the terms for Dutch customers, euros you deposit are held by Stichting Bitvavo Payments in a safekeeping account at a bank, separate from Bitvavo's own assets.⁠Source 2
  • Your euro balance itself takes the form of Bitvavo E-Tokens: a claim on Bitvavo that the terms say is not a deposit or investment account.⁠Source 2
  • FinCEN said it intends to propose adding virtual currency to the FBAR rules. As of November 2026, it has not issued such a rule.⁠Source 1
What is open
No guidance says whether a claim like Bitvavo's euro E-Token balance is a financial account for the FBAR. Nor does any guidance say whether crypto belongs in the maximum value of a mixed account.⁠Source 1⁠Source 3
What to keep
Record the account's highest euro balance and its highest total including crypto, and keep the statements and the terms in force that year. Check FinCEN's position each filing season.⁠Source 4⁠Source 1

Deciding what to do

If the account held no euros at any point in the year, it stays off the FBAR under Notice 2020-2.⁠Source 1

If it did hold euros, listing the account is the cautious reading. Leaving it off relies on the E-Token balance not being a financial account. Record which reading you used and why.⁠Source 1⁠Source 2

Whichever you choose, the account only matters in a year when your foreign accounts together exceed $10,000.⁠Source 5

Example

Example

Chloe in Eindhoven

Chloe bought bitcoin on Bitvavo in January. In October she sold some and left €2,400 in euros in the account for three weeks.⁠Source 1

Her bank accounts already put her over $10,000, so she files an FBAR anyway. She takes the cautious reading and lists the Bitvavo account at its €2,400 euro peak.⁠Source 1⁠Source 5

She keeps a note of that peak, the account's highest total including bitcoin, and why she chose the euro figure.⁠Source 4

Common mistake

Treating the crypto-only exclusion as covering any exchange account. Notice 2020-2 covers accounts holding nothing but virtual currency, so a euro balance needs its own decision.⁠Source 1

More on this question

Is crypto in a hardware or software wallet reportable?

No. Under Notice 2020-2, virtual currency alone is not a reportable account type, and a wallet you control is not an account with anyone.⁠Source 1⁠Source 3

Will this change?

FinCEN has said it intends to propose adding virtual currency to the FBAR rules. As of November 2026, no such rule has been issued.⁠Source 1

Does crypto matter for Form 8938?

Form 8938 is a separate IRS form with its own rules and thresholds. Check its instructions separately; the FBAR exclusion does not settle it.⁠Source 6

Related questions

Full rules and more examples: Reportable foreign accounts

Sources

Official sources used for this page.

  1. Source 1: FinCEN, FinCEN Notice 2020-2 — Virtual currency reporting on the FBAR (opens in a new tab)

    Accounts holding only virtual currency are not currently reportable.

    fincen.govChecked Source updated Back to text

  2. Source 2: Bitvavo (provider's terms), Bitvavo Terms & Conditions (opens in a new tab)

    Provider's own statement: euro funds are held by Stichting Bitvavo Payments in a bank safekeeping account; the user's euro balance is a Bitvavo E-Token, a claim on Bitvavo that is not a deposit or investment account.

    bitvavo.comChecked Source updated Back to text

  3. Source 3: eCFR, 31 CFR § 1010.350 — Reports of foreign financial accounts (opens in a new tab)

    Who has a reportable financial interest in accounts, the rule for owners of record and the definition of signature authority.

    ecfr.govChecked Back to text

  4. Source 4: FinCEN, Record Keeping (opens in a new tab)

    Records each filer must keep and the employee exception.

    fincen.govChecked Back to text

  5. Source 5: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)

    U.S.-person and $10,000 tests, spousal exception, irrelevance of income-tax filing status and extensions for certain employees and officers.

    irs.govChecked Back to text

  6. Source 6: IRS, Instructions for Form 8938 (opens in a new tab)

    Form 8938 thresholds, living-abroad tests and reportable assets.

    irs.govChecked Back to text