THOMPSON COBURN TRADE ALERT – IMPORTS
HEADLINE	Customs Switches to Electronic (ACH) Refunds
DATE	January 21, 2026
AGENCY	U.S. Customs and Border Protection
EFFECTIVE DATES	February 6, 2026
BACKGROUND	On March 25, 2025, President Trump issued Executive Order 14247, Modernizing Payments To and From America’s Bank Account, mandating a transition from paper checks to electronic payments for all Federal disbursements and receipts.   While electronic refunds from Customs and Border Protection (“CBP”) have been available for years, only 30% of the refunds in 2024 and 2025 were issued electronically. The new rule is part of CBP’s efforts to modernize its payment processes in line with Executive Order 14247 from March 2025.
DETAILS	On January 2, 2026, CBP published an interim final rule stating that, starting February 6, the agency will issue all refunds electronically as Automated Clearing House (ACH) payments, rather than as U.S. Treasury checks.   The rule will affect refunds issued for erroneously collected duties, fees, charges, or exactions—as well as any refunds CBP might issue for previously collected IEEPA tariffs should the Supreme Court find those tariffs unlawful. In a recent case before the Court of International Trade, AGS Co. Auto. Sol. v. United States (Dec. 15, 2025), the Government stated that it did not intend to oppose the reliquidation of any entries of goods subject to the challenged IEEPA tariffs.   What to do:   Importers who are not already enrolled in the ACH Refund program must:   • Submit an application to create an ACE Portal account, and • Complete the ACH Refund application under the ACH Refund Authorization tab to provide CBP with the designated banking information, or authorize full access to the ACH Refund Authorization tab to another trade account user to enter the banking information. Should an importer choose to designate a third party, such as a licensed customs broker, to receive any refund(s) on the importer’s behalf, it must designate that third party on CBP Form 4811. The third party must also have or create its own ACE Portal account and complete the ACH Refund application through its own account in order to receive the refund(s).   To open an ACE Portal account:   • If you are an importer with an existing CBP Form 5106 on file with CBP but no existing ACE Portal account access: – Fill out this form online: Importer Form. – For guidance, see: Automated ACE Portal Account Application.   It generally takes CBP 3-5 business days to process an ACE Portal Application, but we anticipate delays due to the anticipated large volume of applications to be filed because of the publication of this notice.   For additional guidance, see: Applying for an ACE Secure Data Portal Account | U.S. Customs and Border Protection.
BASIS	5 U.S.C. 553; 31 U.S.C. 3332(f)(1); 19 U.S.C. 1505(b); 19 U.S.C. 1520.
CITE	Federal Register – Federal Register :: Electronic Refunds   White House – Modernizing Payments To and From America’s Bank Account – The White House

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