Form 8938 Exchange Rate: The Treasury Year-End Rate, Maximum Value and Filing Thresholds

Form 8938, the Statement of Specified Foreign Financial Assets, is the FATCA form that travels with your income tax return. Whether you have to file it at all depends on a dollar threshold, and every asset on it is reported at a dollar maximum value. Both depend on one exchange rate, and the instructions say which one. This guide covers the rule, the thresholds, the numbers for tax year 2025 and the way to fetch them without retyping a PDF.

What the instructions say

The Instructions for Form 8938 (revision November 2021, the current continuous-use revision) give four rules:

• The source. "In most cases, you must use the U.S. Treasury Bureau of the Fiscal Service foreign currency exchange rate for purchasing U.S. dollars."
• The date. "Use the currency exchange rate on the last day of the tax year to figure the maximum value of a specified foreign financial asset or the value of a specified foreign financial asset for the purpose of determining the total value of your specified foreign financial assets to see whether you have met the reporting threshold. Use this rate even if you sold or otherwise disposed of the specified foreign financial asset before the last day of the tax year."
• The order. The maximum value "must be determined in the foreign currency and then converted to U.S. dollars."
• The fallback. "If no U.S. Treasury Bureau of the Fiscal Service exchange rate is available, you must use another publicly available foreign currency exchange rate for purchasing U.S. dollars and disclose the rate on Form 8938."

There is one convenience: you may rely on the conversion rate shown in a financial account statement issued at least annually by the institution that maintains the account.

The Treasury rate in question is the Treasury Reporting Rates of Exchange, a quarterly table from the Bureau of the Fiscal Service. For a calendar-year taxpayer the relevant table is the one dated December 31.

The mistake the rule prevents

The natural instinct is to convert the highest balance at the rate on the day the balance peaked. The instructions say otherwise: find the peak in the foreign currency first, then convert that figure at the year-end rate. An account that peaked in March is converted at the December 31 rate. So is an account you closed in June.

Filing thresholds

You file if the total value of your specified foreign financial assets is more than the amount in either column:

Treasury rates on December 31, 2025

Treasury quotes foreign currency units per one US dollar, so you divide the foreign amount by the rate.

Worked example

An unmarried US citizen holds one German bank account. In 2025 the balance peaked at EUR 180,000 in April and stood at EUR 150,000 on December 31.

If the filer lives in the United States, both figures are far above $50,000 and $75,000: Form 8938 is required, and the account is listed with a maximum value of $211,516. If the filer lives abroad, $176,263 is below $200,000 and $211,516 is below $300,000: no Form 8938 for this account alone.

The rate matters more than it looks. At the December 31, 2024 rate of 0.961 the same EUR 180,000 was $187,305. The euro's rise during 2025 added 13% to the dollar value of an unchanged euro balance, which is enough to push a filer over a threshold without a single deposit.

Form 8938 and the FBAR are separate filings

The FBAR (FinCEN Form 114) has its own $10,000 aggregate trigger and goes to FinCEN, not the IRS. Its instructions point to the same Treasury year-end rate, so one table serves both. Filing one does not replace the other. The FBAR side is covered in the FBAR exchange rate guide.

Getting the year-end table

The table in force today:

curl "https://allratestoday.com/api/open/central-bank/ustreasury"

The table for a past year-end, as JSON or as a spreadsheet for the working papers:

curl -H "Authorization: Bearer YOUR_KEY" \
  "https://allratestoday.com/api/v1/central-bank/ustreasury/2025-12-31"

curl -H "Authorization: Bearer YOUR_KEY" \
  "https://allratestoday.com/api/v1/central-bank/ustreasury/2025-12-31?format=xlsx" -o treasury-2025-12-31.xlsx

Dated tables and history are on paid plans. A conversion helper is then three lines:

rates = {r["quote"]: r["value"] for r in table["rates"]}   # units per 1 USD
def to_usd(amount, ccy):
    return round(amount / rates[ccy], 2)
to_usd(180000, "EUR")   # 211515.86

Checklist

• Find each asset's maximum value in its own currency.
• Convert every figure at the Treasury rate for the last day of the tax year, including assets disposed of during the year.
• Divide by the Treasury rate; do not multiply.
• If Treasury lists no rate for the currency, use another publicly available rate and disclose it on the form.
• Keep a copy of the table with its date in your records.

FAQ

Which exchange rate do I use for Form 8938?

The instructions say that in most cases you must use the U.S. Treasury Bureau of the Fiscal Service exchange rate for purchasing U.S. dollars, as of the last day of the tax year. That is the Treasury Reporting Rates of Exchange table dated December 31 for a calendar-year filer.

Do I convert the maximum value at the rate on the day of the peak?

No. The maximum value is determined in the foreign currency and then converted at the rate on the last day of the tax year, even if the asset was sold or closed before year-end.

What if Treasury does not list my currency?

The instructions require another publicly available exchange rate for purchasing U.S. dollars, and that you disclose the rate on Form 8938.

What was the Treasury euro rate on December 31, 2025?

0.851 euros per US dollar, against 0.961 on December 31, 2024. Divide the euro amount by the rate to get dollars.

Is the Form 8938 rate the same as the FBAR rate?

Both sets of instructions point to the Treasury year-end rate, so the same table is used. They remain separate filings with different thresholds and different recipients.