First IEEPA Refund Payments Could Land May 11 — What to Confirm Before They Do

CBP has signaled that the first IEEPA tariff refund disbursements could begin as early as May 11, 2026 — meaningfully earlier than the 60-90 day total processing window most importers were planning around. That gives every importer a hard, near-term deadline to make sure the refund actually lands in their account when CBP starts pushing money out.

This post walks through what we know, who is realistically in the first wave, and what to confirm in the next 10 days.

Where the May 11 Date Came From

The timeline was reported on April 29, 2026 by Sandler Travis & Rosenberg’s Two Minutes in Trade podcast, citing CBP. It is a directional signal from CBP, not a binding commitment, and it sits on top of two other developments that landed at the end of April:

• April 24: Court of International Trade Judge Eaton ordered CBP to file a CAPE Phase 1 progress report by April 28 — keeping judicial pressure on CBP to keep refund processing moving.
• April 24: NCBFAA published a new April 24 process for updating the Trade Account Owner on existing ACE Portal accounts, layered on top of the modernized ACE Secure Data Portal application released April 1.

Read together, those three updates point in the same direction: CBP is moving to actually pay out, and the gating items on the importer side are now ACE account hygiene and ACH enrollment.

Who Is Realistically in the First Wave

A May 11 disbursement only happens for entries where everything below was true before CBP processed them:

1. The CAPE declaration was submitted in the first days of CAPE Phase 1 (which opened April 20)
2. The declaration was accepted cleanly — not stuck in Accepted with Error(s) or any of the other statuses described in our CAPE upload errors guide
3. The entries are inside Phase 1 scope — unliquidated, or liquidated within roughly the last 80 days
4. The importer of record (IOR), or the designated 4811 party, has an active ACH refund account on file in ACE Portal

If any of those is missing, the refund rolls to a later wave.

That is why the May 11 signal is, for most importers, a story about ACH and ACE account setup — not about CSV formatting or HTS questions.

What to Confirm in the Next 10 Days

Use this as a tight checklist:

1. Verify ACH refund account is live in ACE

Log in to the ACE Secure Data Portal, confirm the ACH refund account is registered and active for the IOR (or for the 4811 party if you designated one). About 80% of eligible importers were not enrolled in ACH as of CBP’s mid-April court filing — see our ACH enrollment post for the underlying numbers and the step-by-step.

2. Check the Trade Account Owner is current

If your ACE Portal account was set up years ago and the original Trade Account Owner has left the company, ACH refund recipient changes may not stick until you complete the new April 24 owner-update process. Walkthrough: Update the Trade Account Owner on an existing ACE Portal account →.

3. Pull the CAPE declaration’s Claim Status

Inside the CAPE tab in ACE, check the Claim Status for every declaration you have submitted. Anything labeled Accepted with Error(s), Rejected by batch validation, or Failed initial validation will not produce a May 11 refund. The fix path is in our Accepted with Error(s) guide.

4. Reconcile the expected refund amount

Even when disbursements start, the amount may not match what you (or your broker) calculated. Causes are catalogued in our refund estimate mismatch post — read it before you challenge a payment that looks short.

5. File or confirm a backup protest

Even with May 11 disbursements imminent, a protest under 19 USC § 1514 within 180 days of liquidation still matters. Various factors can delay or affect the CAPE process, and the protest is the only thing that preserves your right to escalate to the Court of International Trade for a specific entry if CAPE does not deliver. See: How to file a protest for IEEPA tariff refunds →.

What If You Have Not Filed a CAPE Declaration Yet

You will almost certainly not be in the May 11 first wave — but Phase 1 itself is still open and there is no announced filing deadline. The priority sequence is:

1. Run your entries through the eligibility checker to confirm Phase 1 fit
2. Set up or verify the ACH refund account
3. Prepare and validate the CSV (CSV preparation guide →)
4. Submit through ACE
5. In parallel, file a protective protest for any liquidated entries inside the 180-day window

That sequence gets you into the next disbursement wave instead of the first one — which, for the vast majority of importers, is a fine outcome.

A Word on Uncertainty

The May 11 signal is good news, but it is a signal from CBP, not a commitment. The same week brought public commentary from the administration suggesting refunds will be administratively “difficult,” and the CIT is keeping CBP under court order on Phase 1 progress. Both facts argue for the same operational posture importers have been hearing for weeks: use CAPE, but do not rely on CAPE alone.

Filing a CAPE declaration and a protest and (where appropriate) preparing for a CIT path is what trade attorneys keep recommending — not because CAPE will fail, but because the cost of being wrong on any single channel is much larger than the cost of running two or three.

Update — May 3, 2026: May 11 Confirmed, June 6 DOJ Appeal Window, and Two New ACE Reports

Three developments in the first three days of May tighten the picture:

• Diaz Trade Law (May 1) confirmed via a CIT closed-conference summary that the first reciprocal (IEEPA) tariff refunds will issue on or around May 11, 2026 — consistent with the original ST&R signal.
• ST&R (May 1) reported that DOJ has until June 6, 2026 to appeal the CIT refund order. An appeal will not stop already-issued refunds, but it could affect the pace of subsequent waves — another reason to also have a protest filed.
• CBP has activated two ACE reports importers can use to verify status without waiting for an email: ES-022 (CAPE claim status) and ES-701 (courtesy notice of liquidation, now showing reliquidation entries with refund and interest figures). Step-by-step in our ES-022 and ES-701 tracking guide.

If you are positioned for the May 11 wave, pull ES-022 the morning of May 11 and ES-701 daily that week — those reports will tell you the refund is real before the deposit shows up.

Update — May 7, 2026: CIT Closed-Conference Confirmation and a Section 232 Side Note

Two developments since this post was last updated tighten the picture for the May 11 wave:

• Diaz Trade Law (May 1, 2026) confirmed via a summary of a CIT closed conference between CBP and Judge Eaton that the first reciprocal (IEEPA) tariff refunds will be issued on or around May 11. That is now a court-conference-level signal, not just an ST&R podcast inference.
• Commerce Department (May 1, 2026) published a Federal Register notice adding a duty-free HTSUS code for goods that fell under the Section 232 aluminum, steel, or copper tariff regimes but do not actually contain those metals. The provision applies retroactively to April 6, 2026. This is a separate refund track from CAPE — it does not change CAPE Phase 1, but if your entries were mis-classified into a 232 line, it is a parallel recovery path worth flagging to your broker.
• USTR (May 6, 2026) also formally launched the second four-year review of Section 301 China tariffs. That is forward-looking and does not affect the May 11 disbursement, but it changes the post-refund landscape — see Section 301 China tariff comeback: action items after your IEEPA refund.

For the day-of monitoring stack (ES-022, REV-603, REV-613, REV-615), use our CAPE refund monitoring reports guide.

---

Want a vetted trade-law professional to confirm your Phase 1 entries are positioned for the first disbursement wave? Get a free assessment → — we will route you to a specialist based on your exposure and timeline.