80% of Importers Not Ready for IEEPA Refunds: ACH Enrollment Required

If you have not set up ACH electronic payment in ACE, an otherwise approved IEEPA refund can be held before Treasury disbursement — and you are not alone. At the CAPE launch, CBP reported that only about 20% of eligible importers had completed this critical step.

The Numbers Are Alarming

CBP disclosed that roughly 300,000 firms are eligible to receive electronic IEEPA refunds. Of those, only about 57,000 have registered for ACH disbursement — the only payment method CBP will accept.

That meant approximately 240,000 importers could face an ACH payment hold after the CAPE system launched on April 20, simply because they had not enrolled in electronic payments.

CBP has been clear: paper refund checks are no longer issued. Electronic ACH disbursement became the exclusive refund method on February 6, 2026.

Why This Matters Right Now

Even if your entries qualify for CAPE and your CSV file is ready, an approved refund may not be transmitted to Treasury if:

• Your ACH refund account is not registered in ACE
• Your banking information is incomplete or invalid
• The designated refund recipient (importer or 4811 party) doesn’t have active ACH on file

CBP Executive Director Brandon Lord stated in the court filing that the agency “continues to issue messaging to the trade community regarding this new requirement,” but clearly the message hasn’t reached most importers — especially smaller firms.

Smaller Importers at Greatest Risk

Trade attorney Greg Husisian of Foley & Lardner, who represents companies seeking approximately $1 billion in IEEPA refunds, noted that most large companies have likely already enrolled. But smaller importers may not even be aware of the requirement.

If you’re a small or mid-size importer, this is your wake-up call.

How to Enroll in ACH Refund Payments

Setting up your ACH account takes about 10-15 minutes if you already have ACE access. The exact path is documented in CBP Publication No. 5292-1225 (ACE Portal — ACH Bank Information for Electronic Refunds):

1. Log in to the ACE Secure Data Portal
2. Open the Importer Account view in your top account
3. Select the ACH Refund Authorization tab
4. Click Get Info/Refresh to check for existing data, or Add ACH Info if none exists
5. Enter your ABA routing number, account number, and account type
6. Submit; allow 1-2 business days for CBP to validate

Permissions note: only users with Full Access to the ACH Refund Authorization tab can add or update banking information. The Trade Account Owner (TAO) has Full Access by default and can grant the same to a PTAO or Trade Account User from Tools → User Access → Roles → Importer subaccount → Edit.

Why the legal trigger matters: Executive Order #14247 (Modernizing Payments To and From America’s Bank Account, March 25, 2025) is what forced CBP to retire paper checks on February 6, 2026. Even if a paper check would have been faster in your specific case, it is no longer an option.

For a complete walkthrough with screenshots, see our ACE Portal Account Setup Guide.

Don’t have ACE access yet? You’ll need to request an account first. Our setup guide covers that process too, but be aware that new ACE account approvals can take several days.

What If Your Broker Files for You?

Even if your customs broker is handling the CAPE declaration, the ACH refund account must be registered for whoever will receive the payment:

• If the refund goes to you (the importer of record): Your ACH must be registered in ACE
• If the refund goes to a designated 4811 party: That party’s ACH must be registered

Your broker cannot receive the refund on your behalf unless they are the designated 4811 party with valid ACH information. For details on broker coordination, see our Customs Broker Authorization Guide.

The Bigger Picture: $166 Billion at Stake

The total IEEPA tariff duties collected — and potentially refundable — amount to approximately $166 billion, according to CBP’s court filings. With only 20% of eligible importers ready to receive electronic refunds, the vast majority of that money could remain in government hands indefinitely.

The Court of International Trade has scheduled another hearing on the refund process for April 28, 2026. How the ACH enrollment gap is addressed may be a topic of discussion.

Your Action Items

Complete these steps before you expect a CAPE disbursement:

1. Check your ACH status — Log in to ACE and verify your refund banking information is active
2. If not enrolled, set up ACH now — Follow our step-by-step ACH setup guide
3. Verify with your broker — Confirm who will receive the refund and that the correct party has ACH registered
4. Check your eligibility — Use our eligibility checker to confirm your entries qualify for Phase 1

Don’t let a missing bank account be the reason you lose your IEEPA tariff refund.

Update — April 30, 2026: First Disbursements Could Land May 11

Ten days after CAPE Phase 1 went live, two updates make ACH enrollment even more time-sensitive:

• First refund disbursements could begin as early as May 11, 2026. That timeline was reported on April 29 by Sandler Travis & Rosenberg’s Two Minutes in Trade podcast, citing CBP. Importers without an active ACH refund account on file when their declaration is approved will not receive a payment in that first batch.
• CBP released a modernized ACE Secure Data Portal account application on April 1, with a new April 24 process for updating the Trade Account Owner on existing accounts (per NCBFAA’s Monday Morning eBriefing). If the person originally listed as your Trade Account Owner has left the company, you may need to complete that update before the refund recipient ACH change can stick. See our walkthrough: How to update the Trade Account Owner on an existing ACE Portal account →.

If your ACE account or ACH information has not been touched in the last 30 days, treat this week as your last clean window to verify both before the May 11 disbursement wave.

Update — May 12, 2026: Court Confirms 1,880 Refunds Are Stuck Right Now

The May 12, 2026 declaration from CBP Trade Programs Executive Director Brandon Lord (CIT Court No. 25-00595, ECF No. 28) put a hard number on the ACH gap this post warned about: 1,880 consolidated refunds have not been transmitted to Treasury because the importer of record (or its 4811-designated party) has not provided ACH account information to CBP.

Judge Eaton’s same-day order (ECF No. 29) makes the directive explicit: “It is apparent that importers of record should confirm that they have provided the required ACH account information to Customs.”

What to do this week if you have any IEEPA exposure:

1. Open ACE → Importer Account → ACH Refund Authorization. Click “Get Info/Refresh.” If no record appears, you are in the 1,880.
2. If a 4811-designated party (typically your broker) is set as your refund recipient, confirm with that party that their ACH information is current and on file with CBP for your IOR.
3. Pull the REV-613 ACH Rejected Refunds report in ACE Reports. If your importer ID appears on it, the issue is not enrollment — it is account-data accuracy. Update under the same ACH Refund Authorization tab and CBP will reissue the refund.

Until ACH information is on file, your CAPE-accepted, liquidated entry will sit at CBP without disbursement. The court has flagged the problem; the fix is on the importer.

Source: Lord Declaration, May 12, 2026, ¶6.

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Update — July 7, 2026: ACH Blocks Increased to 8,384 Refunds

CBP’s July 1, 2026 Lord Declaration to the Court of International Trade shows that ACH remains one of the largest preventable CAPE payment blockers. As of 3:00 p.m. EDT on June 29, 8,384 refunds had not been transmitted to Treasury because ACH account information had not been provided by the importer of record or its authorized CBP Form 4811 designee.

This is no longer an early-launch edge case. By the same declaration, CBP had accepted approximately $104.29 billion in potential and certified refunds for CAPE processing, and approximately $71.06 billion had been completed, certified, and sent to Treasury. Missing ACH information is therefore the difference between an approved refund pipeline and an actual disbursement.

Action steps:

1. Open ACE and verify ACH Refund Authorization for the importer account or Form 4811 notify party.
2. Pull REV-613 for ACH rejected refunds and REV-603 for Treasury status.
3. If your broker is the 4811 notify party, confirm the broker’s ACH record is active for your refund recipient setup.
4. Do not wait for CBP to fix this automatically; the declaration says the missing information prevented Treasury transmission.

Source: Lord Declaration, July 1, 2026, ¶6.

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Update — July 10, 2026: CBP Clarifies the Narrow Paper-Check Exception

CBP’s July 8 Federal Register notice confirms that IEEPA refunds are held when the importer or authorized Form 4811 designee has no ACH information on file in ACE. That makes ACH the normal payment route for CAPE refunds; it is not a filing-field issue that CAPE will fix for you automatically.

The notice also describes a limited exception, not a routine payment choice: an importer that believes it meets a waiver criterion under 31 CFR part 208 may request a U.S. Treasury check by writing to CBP’s Revenue Division at frn-achrefundsupport@cbp.dhs.gov. Do not assume that a request alone qualifies you for a check. Confirm the applicable waiver with CBP or qualified counsel, and keep ACH information current while that question is resolved.

Source: CBP, Federal Register Doc. 2026-13771, filed July 7, 2026.

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Update — July 17, 2026: 9,837 Refunds Await ACH Information

CBP’s July 13 CAPE progress declaration reports that, as of 3:00 p.m. EDT on July 10, 9,837 refunds had not been transmitted to Treasury because the importer of record or its authorized CBP Form 4811 designee had not supplied ACH account information. This replaces the earlier July 1 snapshot of 8,384 held refunds. The same declaration also reports approximately $121.75 billion accepted for CAPE processing and $86.3 billion completed and sent to Treasury as of July 10, up from the $104.29 billion accepted and $71.06 billion sent reported in the July 1 declaration. Missing ACH information is therefore the difference between an approved refund pipeline and an actual disbursement.

The distinction matters: missing ACH information is not necessarily a rejected CAPE Declaration. It can leave an otherwise processed refund waiting at the disbursement step. The Court of International Trade therefore urged CAPE filers to make sure ACH information has been provided to CBP.

1. Verify the ACH Refund Authorization for the actual refund recipient.
2. If a Form 4811 designee will receive payment, confirm that party’s record as well.
3. Use REV-613 to investigate a returned or rejected ACH payment, but do not submit a duplicate CAPE Declaration just because a payment is on hold.

Sources: CBP Executive Director Brandon Lord, July 13, 2026 declaration, ¶ 6; CIT, July 15, 2026 order.

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Update — August 5, 2026: 19,726 Refunds Await ACH Information

The ACH backlog has more than doubled. CBP’s August 4 progress declaration reports that, as of 3:00 p.m. EDT on July 31, 19,726 refunds totaling approximately $1.6 billion had not been transmitted to Treasury because the importer of record or its authorized CBP Form 4811 designee had not supplied ACH account information. That is up sharply from the 9,837 held refunds reported as of July 10.

The August 4 declaration also reports approximately $128.68 billion accepted for CAPE processing and approximately $100 billion completed, certified, and sent to Treasury as of July 31. The Court of International Trade’s August 5 order again urged CAPE declaration filers to ensure ACH account information has been provided so refunds can be disbursed.

1. Verify the ACH Refund Authorization for the actual refund recipient.
2. If a Form 4811 designee will receive payment, confirm that party’s record as well.
3. Use REV-613 to investigate a returned or rejected ACH payment, but do not submit a duplicate CAPE Declaration just because a payment is on hold.

Sources: CBP Executive Director Brandon Lord, August 4, 2026 declaration, ¶ 6; CIT, August 5, 2026 order.

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