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Effective February 6, 2026, Customs and Border Protection (“CBP”) will issue refunds electronically via Automated Clearing House (“ACH”). This rule change will affect all refunds, subject to limited exceptions (e.g., certain emergency payments, transactions involving national security or law enforcement concerns, transactions involving individuals who do not have access to banking services or electronic payment systems, etc.). FR Document 2025-24171. Also this rule will apply to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, and carriers as well as designated third parties listed on a CBP Form 4811. In short, absent a waiver, after February 5, 2026 CBP will not issue refunds by check. 

To receive an ACH electronic refund importers will need to use CBP’s Automated Commercial Environment Secure Data Portal (the “ACE Portal”). 

  • Importers currently enrolled in the ACH Refund program will continue to receive electronic refunds via ACH without interruption. 
  • Importers wishing to change banking information on file with CBP will need to complete the ACE Portal ACH refund application. 
  • Importers not yet enrolled in the ACH Refund program will need submit an application for an ACE Portal account if an account does not already exist. Once an ACE Portal account has been created, the account owner will need to complete the ACH Refund application in the ACE Portal under the ACH Refund Authorization tab. 

ACE Portal account owners may authorize access to the ACH Refund Authorization tab to another trade account user to enter the designated banking information. However, any third party designated on a CBP Form 4811 must also have an ACE Portal account and complete the ACH Refund application. As part of the ACH Refund application, all applicants will be required to use a U.S. bank account. 

Significantly, the obligation to provide CBP with the necessary banking information to receive refunds electronically is placed on the importer. Failure to provide CBP with the requisite ACH banking information will result in a refund being rejected. If CBP certifies a refund for issuance within 30 days of liquidation or reliquidation, but is unable to deliver an electronic refund to the importer or designated third party, solely due to the importer’s or third party’s failure, then no interest will accrue to the importer. In that regard, it will be the importer’s responsibility to ensure the accuracy of the information provided and to contact CBP if any information needs to be updated or a designation is revoked. CBP has published certain support materials in anticipation of the change: CBP’s Electronic Refund Enrollment Reference Sheet. They have also scheduled a number of Teams calls to assist the trade community. See Cargo Systems Messaging Service (CSMS) # 67305746 for dates and Teams links.

We believe these changes could be important in the event of anticipated IEEPA tariff refunds.

For questions or additional information please contact the Husch Blackwell Trade team.