Why are paper refund checks no longer issued for IEEPA refunds?

Executive Order #14247 ('Modernizing Payments To and From America's Bank Account,' March 25, 2025) directed the federal government to discontinue paper checks. CBP transitioned to electronic-only refund disbursement on February 6, 2026. From that date forward, the only way CBP can pay out an IEEPA refund is by ACH direct deposit through bank information enrolled in the ACE Portal.

Where in the ACE Portal do I add or update ACH refund banking information?

Log in to ACE, open the Importer Account view, and select the 'ACH Refund Authorization' tab. From there: click 'Get Info/Refresh' to see existing data, 'Add ACH Info' to enroll a new account, or 'Edit' to update existing data. The actual ACH data is stored in CBP's financial system, not in ACE — ACE Portal is the entry point. Source: CBP Publication No. 5292-1225.

What is the difference between Read-Only and Full Access on the ACH Refund Authorization tab?

The Trade Account Owner (TAO) has Full Access by default. The TAO can grant Proxy Trade Account Owners (PTAO) or Trade Account Users either Read-Only access (view ACH information only) or Full Access (add or edit ACH information). For most importers, the AP/treasury contact who maintains banking information needs Full Access; everyone else can stay on Read-Only.

Can my customs broker file ACH refund information on my behalf?

A broker acting as a 4811 Notify Party can manage ACH refund information for the refund recipient, but the broker must first be granted importer-record view access on the ACE account. The broker cannot register ACH information for an account they do not have visibility into. If the refund is going to your importer-of-record account directly, your own TAO or authorized user must enroll the ACH information.

How do I tell if my ACH refund failed and what should I do about it?

CBP publishes failed disbursements in the REV-613 ACH Rejected Refunds report, available in ACE Reports under Public Folders → ACE → Trade → Importer/Broker → Revenue → Refunds. If your refund appears on REV-613, the typical fix is to update the ACH information in the ACH Refund Authorization tab, then wait for CBP to issue a replacement refund. Per CBP guidance, replacement refunds follow a separate processing path.

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

If you haven’t set up ACH electronic payment in ACE, your IEEPA tariff refund will be rejected — and you’re not alone. According to a CBP filing at the Court of International Trade on April 15, 2026, only about 20% of eligible importers have 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 means approximately 240,000 importers could have their refund requests rejected when the CAPE system launches on April 20, simply because they haven’t 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

The CAPE system opens tomorrow, April 20, 2026. Even if your entries qualify for Phase 1 and your CSV file is ready, your refund declaration will fail 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):

Log in to the ACE Secure Data Portal
Open the Importer Account view in your top account
Select the ACH Refund Authorization tab
Click Get Info/Refresh to check for existing data, or Add ACH Info if none exists
Enter your ABA routing number, account number, and account type
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 today — before CAPE goes live tomorrow:

Check your ACH status — Log in to ACE and verify your refund banking information is active
If not enrolled, set up ACH now — Follow our step-by-step ACH setup guide
Verify with your broker — Confirm who will receive the refund and that the correct party has ACH registered
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.

Need help navigating the refund process? Get a free assessment from vetted trade law professionals who specialize in IEEPA tariff recovery.