Signature Authority

Signature authority is the power to control money or assets in a foreign financial account by communicating directly with the bank or financial institution. For U.S. expats, it matters because signature authority over someone else’s foreign account can trigger FBAR reporting even when the expat does not own the money.

Why it matters for U.S. expats

Signature authority often comes up when U.S. expats can approve payments, move funds, or sign on a business, employer, charity, trust, estate, or family account outside the United States. The account may belong to someone else, but FBAR can still apply if the U.S. person has authority over the account and the aggregate foreign account value exceeds the reporting threshold.

Common questions

1. What does signature authority mean for FBAR?

For FBAR, signature authority means an individual can control the disposition of assets in a foreign financial account by direct communication with the financial institution.

2. Is signature authority the same as owning a foreign account?

No. Ownership means the person has a financial interest in the account. Signature authority means the person can control or direct account activity, even if they do not own the funds.

3. Can signature authority alone trigger FBAR?

Yes. A U.S. person with signature authority over a foreign financial account may need to file FBAR if the aggregate value of reportable foreign financial accounts exceeds $10,000 at any time during the year.

4. Does the account need to belong to the U.S. person?

No. FBAR can apply when the account belongs to an employer, company, trust, estate, nonprofit, spouse, parent, or another person, if the U.S. person has signature authority.

5. What kinds of accounts can create signature authority?

Foreign bank accounts, brokerage accounts, investment accounts, pension accounts, insurance accounts with cash value, and other foreign financial accounts can create signature authority if the person can direct or approve transactions.

6. Does online banking access count as signature authority?

It can. If online access allows the person to move funds, approve payments, or otherwise control assets by communicating with the financial institution, signature authority may exist.

7. Does view-only access count as signature authority?

No. View-only access does not usually give the person authority to control the disposition of assets. The key issue is whether the person can direct transactions or move funds.

8. Does an employee need to report an employer’s foreign account?

Possibly. A U.S. employee or officer with signature authority over an employer’s foreign account may need to file FBAR unless a specific employee exception, consolidated FBAR rule, or filing extension applies.

9. Are there exceptions for employees with signature authority only?

Yes. The FBAR instructions include exceptions for certain officers and employees of regulated banks, financial institutions, listed companies, and related entities when they have signature authority but no financial interest in the account.

10. Does signature authority require Schedule B reporting?

Yes. Schedule B asks whether the taxpayer had a financial interest in or signature authority over a foreign financial account. This question can apply even when the account produced no income.

11. Does signature authority alone require Form 8938?

Not usually. Form 8938 applies to specified foreign financial assets in which the taxpayer has an interest. Signature authority alone may trigger FBAR and Schedule B review, but Form 8938 depends on the taxpayer’s ownership or other reportable interest.

12. How is signature authority reported on FBAR?

The account is reported on FinCEN Form 114. Accounts over which the filer has signature authority but no financial interest are reported in the signature-authority section of the FBAR.

13. Does the full account value need to be reported?

Yes. FBAR reporting uses the maximum value of the account during the year. A person with signature authority does not report only a share of the account.

14. What if several people have signature authority over the same account?

Each U.S. person with a separate FBAR obligation may need to report the account unless an exception applies.

15. What if signature authority existed for only part of the year?

The account may still be reportable for that year if the person had signature authority at any time during the calendar year and the FBAR threshold was met.

16. What records should U.S. expats keep for signature authority?

Keep account authorization documents, employment or officer records, bank mandate forms, account statements, maximum value calculations, country details, institution details, evidence showing when authority began or ended, and any employer confirmation of consolidated or exception-based reporting.

Related forms

• FinCEN Form 114: FBAR reporting
• Schedule B: Interest and ordinary dividends
• Form 8938: FATCA reporting for U.S. expats
• Form 1040: U.S. Individual Income Tax Return

When to get help

Professional guidance is important when:

• You can sign on or approve transactions for a foreign account you do not own.
• You have authority over an employer’s, company’s, trust’s, estate’s, nonprofit’s, or family member’s foreign account.
• You are unsure whether your access is view-only or gives control over funds.
• You need to determine whether an employee exception applies.
• You have both signature authority and financial interest in foreign accounts.
• You missed prior-year FBAR reporting.
• You answered Schedule B incorrectly in a prior year.

Bright!Tax can review your foreign account authority, determine whether FBAR applies, and prepare or amend FBAR and related expat tax reporting where needed. Get started with Bright!Tax.

Related Bright!Tax guides

• FBAR filing requirements for Americans living abroad
• FBAR vs. Form 8938: Which one applies to you
• Delinquent FBAR Submission Procedures

Official sources

• IRS: Report of Foreign Bank and Financial Accounts
• FinCEN: Report Foreign Bank and Financial Accounts
• FinCEN: FBAR line item filing instructions
• IRS: Instructions for Schedule B
• IRS: Comparison of Form 8938 and FBAR requirements

Reviewed by

Katelynn Minott, CPA & CEO

Last reviewed

July 2026