The short answer

Yes, you may still need to report it. "No income" does not mean "no FBAR." The FBAR depends on the value of your foreign financial accounts — whether their aggregate value exceeded $10,000 at any time during the year — not on whether they earned interest.

It helps to separate two kinds of reporting that people often mix up:

Account reportingIncome reporting
What it coversThe existence and value of foreign accountsIncome the accounts earned (interest, dividends, gains)
WhereFBAR (with FinCEN); Form 8938 (with the tax return); Schedule B, Part III questionYour income tax return
Triggered byAccount values and thresholdsActual income earned while you were a U.S. citizen or resident
Zero-interest accountCan still be requiredNothing to report as interest if none was earned

Account reporting: FBAR

If the maximum values of all your foreign financial accounts add up to more than $10,000 at any time during the calendar year, you file an FBAR — including accounts that paid no interest at all. See How the $10,000 rule really works.

Account reporting: Form 8938

Form 8938 can also apply to assets that produced no income that year, if your specified foreign financial assets exceed your threshold and you are required to file an income tax return. Its thresholds are much higher than the FBAR's. See FBAR vs. Form 8938.

The Schedule B question

If you file Schedule B, Part III asks whether you had a financial interest in or signature authority over a foreign financial account at any time during the year. Answer it based on the account — the Schedule B instructions say to answer "Yes" even if you are not required to file an FBAR.

Income reporting: only what was actually earned

U.S. citizens and residents are taxed on worldwide income. If the account earned interest — even a small amount — you report it in U.S. dollars on your tax return. If it truly earned nothing, there is no interest to report. Either way, that answer does not change the FBAR question.

Example

Ben keeps a Taiwan checking account that pays no interest. It peaked at the equivalent of $14,000 in 2025. He has no other foreign accounts. Result: no foreign interest to report on his tax return, but the account exceeded $10,000, so he files an FBAR and answers "Yes" to the Schedule B foreign-account question. His foreign assets are well below the Form 8938 threshold.

⚠️ A common misconception

"My account didn't make any money, so the IRS doesn't care about it" is one of the most common reasons people miss FBARs. If you have already missed one, see I forgot to file an FBAR — what should I do?