Effective February 6, 2026, CBP will process all refunds electronically. The agency will not issue any refunds by check unless a waiver has been approved.
Background
Historically, the majority of CBP refunds for the overpayment of duties, taxes, and fees were transmitted via paper checks issued by the U.S. Department of the Treasury. The issuance of electronic refunds via ACH has been available for some time, but opting-in for electronic refunds has been voluntary and limited in scope. In 2024 and 2025, approximately 30% of the refunds CBP issued annually were issued electronically.
On March 25, 2025, President Trump issued an Executive Order titled "Modernizing Payments To and From America's Bank Account." The order mandates the transition from paper checks to electronic payments for all Federal disbursements and receipts.
Electronic Refunds
To implement the electronic payments Executive Order, CBP published an Interim Final Rule on January 2, 2026, announcing that the agency will issue all refunds electronically (subject to certain exceptions under 31 CFR part 208) effective February 6, 2026. This rule applies to refunds issued to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, and carriers, and any designated third parties listed on CBP Form 4811. After this date, CBP will not issue any refunds by check, unless a waiver has been approved. Comments on the Interim Final Rule are due March 3, 2026.
Importers who are not already enrolled in the ACH Refund program must submit an ACH Refund application through the ACE Portal. As part of the ACH Refund application, all applicants are required to use a U.S. bank account (note that foreign Importers of Record may have an ACE account, but a U.S. bank account must be used for the ACH application). Once an application for ACH Refund is successfully submitted and approved in the ACE Portal, all future refunds will be issued electronically to the designated U.S. bank account.
Importers who are currently enrolled in the ACH Refund program will continue to receive electronic refunds via ACH without interruption. More resources on the migration from CBP here.
Set Up Your ACE Account Today!
Importers must set up an ACE account to access the ACH Refund application, but there are many other reasons to set up and utilize an ACE account. ACE is the primary system for the international trade community to submit import and export data to communicate with CBP and other participating government agencies. CBP and the partner government agencies use ACE to collect, track, and process required trade information.
An ACE account gives importers:
- Full visibility into import activity
- Improved compliance through real-time monitoring
- Electronic notice & document management
- Ability to manage payments, refunds, and statements
- Better data for audit preparation
- Streamlined communication with CBP
Additionally, if the IEEPA tariffs are eventually found to be unlawful and are refunded, processing refunds electronically through ACE will be far easier and more efficient for CBP.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
