U.S. Customs and Border Protection Transitions To Electronic Refunds

On January 2, 2026, U.S. Customs and Border Protection (“CBP”) published an interim final rule announcing that, effective today, Friday, February 6, 2026, all refunds (with very limited exceptions) will be issued electronically via Automated Clearing House (ACH) payments.  CBP is transitioning all refund payments to electronic funds transfers to comply with federal law, 31 U.S.C. § 3332(f)(1), and Executive Order 14247 (March 25, 2025), in which President Trump mandates the transition from paper checks to electronic payments for all federal disbursements and receipts.

As importers await the Supreme Court’s decision on the legality of the tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) (and hope for large refunds to come), it is important to prepare for potential refunds.  Here is what you need to know about the transition and recommended actions to ensure your company’s refunds (IEEPA or otherwise) are processed without interruption:

For Importers Currently Enrolled in the ACH Refund Program

If your company is already enrolled in the ACH Refund program, CBP recommends that you do the following:

• Confirm that existing U.S. banking information on file with CBP is correct.  Importers that need to change their banking information may do so via the Automated Commercial Environment (“ACE”) Refund application in the ACE Portal.
• Ensure that your company’s ACE Portal account is linked to the company’s current CBP Form 5106 (Create/Update Importer Identity Form).  If ACE is not linked to the company’s Form 5106, you will need to submit a new ACE Portal account application and send it to CBP (ace.applications@cbp.dhs.gov) to request a new account that is tied to the Form 5106 on file with CBP.
• Confirm that information submitted by the company to CBP on Form 4811 (Special Address Notification) is current, accurate and that the agent designated in that form to receive refunds on behalf of the importer of record (e.g., a licensed customs broker) remains a valid agent for that purpose as refunds will be issued electronically to an agent designated by the importer of record on the Form 4811.
• Confirm that any third-party agent designated on the company’s current Form 4811 to receive refunds on behalf of your company has also completed the ACH Refund application.

For Importers Not Enrolled in ACH

If your company is not currently enrolled in the ACH Refund program, you will need to complete the following steps:

• Submit an application for an ACE Portal account if you do not have one already.
• Once the ACE Portal account is created, file an ACH Refund application to submit the company’s banking information to CBP.  This application can be located under the ACH Refund Authorization tab within ACE.
• As noted above, confirm that any agent designated in the company’s Form 4811 to receive refunds on behalf of the importer of record remains a valid agent, that the information for that agent is complete and accurate, and that the agent has also filed an ACH Refund application with CBP.

As a final note, if your company imports under a single importer of record number with multiple two-digit suffixes, ensure that each importer of record number with a unique suffix has a sub account in ACE and that an ACH Refund application has been filed for each unique suffix.  The same is true if your corporate entity involves multiple distinct importer of record numbers (i.e., where each importer of record number is a different employer tax identification number or CBP-assigned importer of record number).