CBP Electronic Refunds: Mandatory ACH Transition Effective February 6, 2026

This guide provides a comprehensive overview of the new mandate,
its implications for importers, and the essential steps required to ensure a seamless transition.

The End of Paper Checks: What’s Changing and Why

The transition away from paper checks is driven by a broader federal initiative to modernize government payments. The change aligns with Executive Order 14247, “Modernizing Payments To and From America’s Bank Account,” signed by President Trump on March 25, 2025, which directs federal agencies to digitize payments to improve security and reduce costs [3].

The rationale for this transition is compelling. Historically, paper checks have been vulnerable to fraud, theft, and logistical delays. According to the Executive Order, mail theft complaints have increased substantially since the COVID-19 pandemic, and Treasury checks are 16 times more likely to be lost, stolen, returned undeliverable, or altered than electronic funds transfers [3]. The cost of maintaining the physical infrastructure and specialized technology for processing paper records exceeded $657 million in Fiscal Year 2024 alone [3].

The shift to ACH is projected to yield significant cost savings and security benefits for both CBP and the trade community. CBP estimates combined annualized net cost savings of approximately $1.3 million from this transition [2].

Types of Refunds Affected

Under the new Electronic Refunds Interim Final Rule, after February 6, 2026, CBP will no longer issue paper checks for refunds, and all refunds will be transmitted electronically via the ACH network. This transition applies to:

Who Is Affected

The rule applies broadly to all CBP refund recipients, including:

• Importers (the primary affected group)
• Customs Brokers
• Filers
• Sureties
• Service Providers
• Facility Operators
• Foreign Trade Zone Operators
• Carriers
• Designated Third Parties (listed on CBP Form 4811)

All parties receiving these refunds must prepare for this change by ensuring they are properly enrolled in the ACH Refund program.

Action Required: Your Step-by-Step Guide to ACH Enrollment

To avoid disruptions and ensure timely receipt of refunds, all trade participants must be enrolled in CBP’s ACH Refund program through the Automated Commercial Environment (ACE) Secure Data Portal. The required actions depend on your current enrollment status.

For Importers Not Yet Enrolled in ACH Refunds

Step 1: Obtain an ACE Portal Account

If you do not already have an ACE Portal account, you must apply for one immediately. CBP offers two methods:

1. Automated Online Application (Recommended): Use the new streamlined importer application form [4]. This form enables trade parties without current ACE Portal access to request the creation of an ACE Portal top account with access to a single Importer sub-account view.
2. Manual Application: Complete the ACE Secure Data Portal Account Application Form and email it to ace.applications@cbp.dhs.gov [5].

Step 2: Enroll in ACH Refunds

Once you have an ACE Portal account:

1. Log into the ACE Secure Data Portal
2. Navigate to the “ACH Refund Authorization” tab
3. Enter your U.S. bank account information, including your bank routing number

Important: Your bank routing number must process FedACH payments. CBP will reject bank information if the routing number does not support FedACH transactions [5].

For Importers Already Enrolled in ACH Refunds

If you are already enrolled in the ACH Refund program, no immediate action is required to continue receiving electronic refunds. However, CBP strongly recommends logging into the ACE Portal to review your ACH authorization information and ensure its accuracy [5].

For Importers Using a Third Party (e.g., Customs Broker)

If you use a customs broker or another agent designated via CBP Form 4811 (Special Address Notification) to receive refunds on your behalf:

1. Your existing CBP Form 4811 designation remains valid
2. However, the designated third party must also have an ACE Portal account and be enrolled in the ACH Refund program
3. If the third party is not enrolled in ACH, the refund will default to your (the importer’s) ACH account
4. It is the importer’s responsibility to coordinate with their agent to ensure compliance [6]

For Foreign Importers

Foreign importers face a unique challenge since ACH refunds require a U.S. bank account. You have two options:

1. Establish a U.S. bank account to receive refunds directly
2. Designate a trusted third party with a U.S. bank account (such as a customs broker) to receive refunds on your behalf using CBP Form 4811 [6]

Key Dates and Deadlines

Understanding the Consequences of Non-Compliance

Failure to provide the necessary banking information in the ACE Portal will have direct consequences:

If CBP certifies a refund for issuance within 30 days of the liquidation or reliquidation of the entry, but is unable to deliver an electronic refund, either to the importer or to a designated third party, solely due to the importer’s or designated third party’s failure to provide CBP with the necessary banking information to effectuate the electronic refund, no interest will accrue under 19 U.S.C. 1505(d). [2]

In other words, if your refund is rejected because you haven’t enrolled in ACH, you will not receive interest on the delayed payment. To resolve a rejected refund, you must:

1. Complete the ACH Refund enrollment process in the ACE Portal
2. Contact CBP’s Refunds Team at frn-achrefundsupport@cbp.dhs.gov to confirm completion and request reissuance of the rejected refund [2]

Benefits of Electronic Refunds

The transition to electronic refunds offers substantial benefits:

The Waiver Process: A Limited Exception

While the mandate is comprehensive, the rule allows for waivers in rare circumstances where electronic payment is not feasible, as outlined in 31 CFR 208.4 [7]. Waiver conditions may apply in the following situations:

• Individuals born before May 1, 1921, who were receiving payment by check on March 1, 2013
• Individuals with a mental impairment preventing them from managing a bank account
• Individuals in remote geographic locations lacking infrastructure for electronic financial transactions
• Payments to recipients in designated disaster areas (limited to 120 days after disaster declaration)
• National security or law enforcement situations
• Foreign payments where infrastructure does not support electronic transfers

How to Request a Waiver

If you believe you qualify for a waiver, you must:

1. Submit a written request to CBP’s Revenue Division at frn-achrefundsupport@cbp.dhs.gov
2. Include sufficient information to identify the importer and associated pending refunds
3. Specify the waiver provision within 31 CFR 208.4 upon which you are relying
4. Demonstrate that your circumstances satisfy the waiver criteria [5]

CBP expects these waivers to be rare, and the burden is on the importer to demonstrate eligibility.

Contact Information and Resources

Conclusion: Prepare Now for a Smoother Future

The mandatory transition to electronic refunds is a critical step forward for the trade community. By eliminating paper checks, CBP is creating a more secure, efficient, and reliable system for all stakeholders. The benefits are clear: faster payments, reduced fraud risk, and lower administrative costs.

Importers must act now to ensure their ACE Portal and ACH refund information is complete and accurate. With the February 6, 2026, deadline upon us, proactive preparation will prevent payment delays and allow your business to fully realize the benefits of this modernized process.

If you have questions about how this transition affects your specific situation, we encourage you to review CBP’s official resources or consult with your customs broker.

References

[1] U.S. Customs and Border Protection. (2026, January 6). CBP modernizes electronic refund enrollment process. https://www.cbp.gov/newsroom/national-media-release/cbp-modernizes-electronic-refund-enrollment-process

[2] U.S. Customs and Border Protection. (2026, January 2). Electronic Refunds. Federal Register, 91 FR 21. https://www.federalregister.gov/documents/2026/01/02/2025-24171/electronic-refunds

[3] The White House. (2025, March 25). Executive Order 14247: Modernizing Payments To and From America’s Bank Account. https://www.whitehouse.gov/presidential-actions/2025/03/modernizing-payments-to-and-from-americas-bank-account/

[4] U.S. Customs and Border Protection. ACE Portal Importer Application Form. https://ace-accounts.cbp.gov/s/importer-form

[5] U.S. Customs and Border Protection. (2026, January 26). ACE Portal and ACH Refunds FAQs. https://www.cbp.gov/trade/automated/ace-portal-and-ach-refunds-faqs

[6] Troutman Pepper Locke. (2026, January 7). CBP Moving to Fully Electronic Refunds: What Importers Need to Know Now. https://www.troutman.com/insights/cbp-moving-to-fully-electronic-refunds-what-importers-need-to-know-now/

[7] Electronic Code of Federal Regulations. 31 CFR 208.4 — Waivers. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-II/subchapter-A/part-208/section-208.4