March 7, 2026·10 min read

How to Set Up Your ACE & ACH Accounts for IEEPA Refunds — Step-by-Step Guide

CBP confirmed on March 6 that only 21,000 of 330,000 affected importers have ACH accounts set up for electronic refunds. That means 93.6% of importers are NOT ready to receive their share of $166 billion in IEEPA tariff refunds. CBP has stated it will only issue refunds electronically. If you're not set up, you won't get paid. Here's exactly how to fix that — today.

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Time-Sensitive: March 12 Status Update

Judge Eaton has ordered CBP to report progress on its automated refund system by March 12, 2026. Once the system goes live, importers without ACH will be at the back of the line. Set up your accounts NOW.

Why You Need ACE & ACH — The 93.6% Problem

In his March 6 declaration to the CIT, CBP Executive Director Brandon Lord revealed a staggering gap: of the 330,000 importers who paid IEEPA tariffs, only about 21,000 have completed the necessary steps to receive electronic refunds.

This matters because:

  • CBP has eliminated paper checks. As of February 6, 2026, all CBP refunds must be issued electronically via ACH. No ACH account = no refund.
  • CBP's proposed 45-day system will be automated. The new ACE functionality CBP is building will process refunds through the portal — importers need an active ACE account with ACH enabled.
  • 309,000 importers are competing for setup. When the refund system goes live, CBP's account setup infrastructure will be overwhelmed. Early movers get paid first.

What You Need Before You Start

Gather these before beginning the ACE registration process:

📋 Required Documents & Information

  • ✅ IRS Employer Identification Number (EIN) — your company's federal tax ID
  • ✅ Importer of Record number — typically your EIN with a 2-digit suffix
  • ✅ Company legal name and address — must match IRS records exactly
  • ✅ Designated company contact — name, email, phone of person managing trade compliance
  • ✅ Bank routing number and account number — for ACH enrollment (business checking account)
  • ✅ Customs broker information — if you use one (broker name, license number)
  • ✅ Bond information — your continuous customs bond number (if applicable)

Step 1: Create or Verify Your ACE Account

If You DON'T Have an ACE Account

  1. Go to the CBP ACE Account Portal: ace-accounts.cbp.gov/s/importer-form
  2. Select “Importer” as your account type. This is the correct option for any company that imported goods and paid IEEPA duties.
  3. Complete the registration form. Enter your EIN, company name (must match IRS records exactly), physical address, and designated contact information.
  4. Submit and wait for CBP verification. Account creation typically takes 3-5 business days. CBP will email your designated contact with login credentials.
  5. Log in and complete your profile. Once approved, sign in at ace.cbp.dhs.gov and verify all company information is current.

If You Already Have an ACE Account

  1. Log in to ACE at ace.cbp.dhs.gov
  2. Verify your account is active and that your company information (EIN, address, contacts) is current.
  3. Check your entry history. Navigate to the entry summary section and confirm you can see entries where IEEPA duties were applied. These will be flagged under HTS codes 9903.01.xx and 9903.02.xx.
  4. Proceed to Step 2 (ACH enrollment) if you haven't already.

Step 2: Enroll in ACH for Electronic Refunds

This is the critical step most importers are missing. ACH enrollment connects your bank account to CBP's payment system so refunds can be deposited directly.

  1. From your ACE account dashboard, look for the Automated Refund Authorization (ARA) or ACH Refund section in your account settings.
  2. Enter your banking information:
    • Bank name
    • 9-digit ABA routing number
    • Account number (business checking recommended)
    • Account type (checking/savings)
  3. Authorize electronic refunds. You'll need to agree to CBP's terms for electronic disbursement. This replaces the old paper check process.
  4. Confirm enrollment. CBP typically processes ACH enrollment within 1-2 business days. You'll receive a confirmation email.

💡 Pro Tip

Use a dedicated business checking account for CBP refunds. Given the potential size of IEEPA refunds (some importers paid millions), having a clear paper trail in a separate account simplifies accounting and tax reporting.

Step 3: Prepare Your Entry Documentation

CBP's proposed automated system will require importers to file a declaration listing affected entries. Start compiling this now:

  1. Pull all entry summaries with IEEPA duties. In ACE, filter your entries for HTS codes 9903.01.xx and 9903.02.xx. These are the IEEPA-specific tariff codes.
  2. Categorize entries by liquidation status:
    • Unliquidated entries: Not yet finalized. These are straightforward — CBP will liquidate them without IEEPA duties.
    • Liquidated entries (within 180 days): Already finalized but still within the protest window. CBP will reliquidate these without IEEPA duties.
    • Liquidated entries (beyond 180 days): Status uncertain. The CIT's order may still cover these, but it's an open legal question.
  3. Calculate your total IEEPA duties paid. Sum up the IEEPA-specific duties across all entries. This is your potential refund amount (plus interest).
  4. Note your liquidation dates. For any entries approaching the 180-day post-liquidation deadline, consider filing a protest immediately to preserve your rights. See our CBP protest filing guide.

Step 4: Coordinate with Your Customs Broker

If you use a customs broker (most importers do), they're a critical part of this process:

  • Ask your broker to pull a report of all your entries with IEEPA duties — they may have more detailed records than what's visible in your ACE account.
  • Confirm your broker hasn't filed any protests on your behalf without your knowledge. Some brokers proactively filed protests after the SCOTUS ruling.
  • Discuss the refund process. Your broker should be aware of CBP's proposed 45-day timeline and the March 12 status update.
  • Clarify who will file the declaration. Under CBP's proposed system, the importer files a declaration listing entries. Confirm whether your broker will handle this or if you need to do it directly.

What CBP's Automated Refund System Will Look Like

Based on Brandon Lord's March 6 declaration, here's the 7-step process CBP is building:

  1. Importer files a declaration in ACE listing all entries with IEEPA duties
  2. ACE validates each entry in the declaration automatically
  3. ACE recalculates duties owed without IEEPA tariffs (with interest)
  4. ACE finalizes entries — liquidates unliquidated entries, reliquidates liquidated ones
  5. ACE aggregates refunds by importer and liquidation date
  6. CBP certifies the refund amounts
  7. Treasury issues refunds electronically via ACH

Key insight: Steps 6 and 7 require an active ACH account. Without it, your refund will be calculated and certified but cannot be disbursed. You'll be stuck in a queue while CBP contacts you to set up electronic payment.

Critical Timeline: What Happens Next

TODAY

Set up ACE & ACH accounts

If you haven't already, start immediately. 3-5 day processing time for new ACE accounts.

MAR 12

CBP reports progress to CIT

Judge Eaton ordered CBP to provide an update on the automated refund system. This will clarify the exact timeline and process.

~APR 20

CBP's 45-day target for automated system

If CBP meets its timeline, the new ACE refund functionality goes live. Importers with ACE + ACH can start filing declarations immediately.

WATCH

DOJ appeal decision

DOJ could petition for SCOTUS rehearing or appeal CIT orders to the Federal Circuit. Strategic window is 7-14 days from March 6. An appeal would NOT stop the refund system build — but could delay disbursement.

5 Common Mistakes That Could Delay Your Refund

  1. Waiting for CBP to contact you. CBP will not proactively reach out to set up your ACH. It's on you to register. The 309,000 importers without ACH will need to self-serve.
  2. Company name mismatch. Your ACE account name must exactly match your IRS EIN records. Even small differences (Inc. vs Incorporated, LLC vs L.L.C.) can cause processing delays.
  3. Using a personal bank account. ACH refunds for importers should go to a business account matching the importer of record. Personal accounts may trigger additional verification.
  4. Ignoring the 180-day protest deadline. If any of your liquidated entries are approaching 180 days post-liquidation, file a protest NOW — even if the CIT's order theoretically covers them. Belt and suspenders.
  5. Assuming your broker handled everything. Your broker may have an ACE account, but the ACH enrollment for refunds must typically be completed by the importer of record. Confirm with your broker who owns this step.

Frequently Asked Questions

How much will my refund be?

Your refund equals the total IEEPA duties you paid, plus interest. Use our Quick Refund Estimator for a ballpark figure. The exact amount will be calculated by CBP's automated system once it's live.

Will I get interest on my refund?

Yes. The government has committed to paying interest on IEEPA refunds. The rate is typically the federal short-term rate plus 2%, compounding daily. At current rates, this is approximately 6-7% annualized — which adds up significantly on refunds that have been held for months.

What if my customs broker already filed a protest?

Good — that's belt and suspenders. The CIT's order should cover your entries regardless of whether a protest was filed. But having a protest on record provides an additional layer of protection, especially for entries that may fall outside the CIT's order scope.

I'm a small importer with only a few entries. Is this worth the effort?

Absolutely. Even if your total IEEPA duties were $5,000-$10,000, the ACE/ACH setup takes about 30 minutes. That's potentially hundreds or thousands of dollars per minute of effort. And the setup is permanent — it benefits all future CBP interactions.

Can I set up ACE/ACH if I'm a sole proprietor or small LLC?

Yes. Any entity that is an importer of record can create an ACE account. Sole proprietors use their Social Security Number in place of an EIN. The process is the same regardless of business size.

Your IEEPA Refund Readiness Checklist

  • ☐ACE account created and verified at ace-accounts.cbp.gov
  • ☐ACH enrollment completed with business bank account
  • ☐Entry list compiled — all entries with HTS 9903.01.xx / 9903.02.xx
  • ☐Liquidation status checked for each entry
  • ☐Protests filed for entries approaching 180-day deadline
  • ☐Customs broker contacted to coordinate refund process
  • ☐Total IEEPA duties calculated across all entries
  • ☐March 12 monitoring set up — follow TariffRefundIQ for updates on the CIT status report

Don't Know Your Refund Amount?

Use our free estimator to calculate your potential IEEPA refund before the March 12 update.

Estimate My Refund →

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