CBP Moves to Mandatory Electronic Refunds: What Importers Need to Know Before February 6, 2026

U.S. Customs and Border Protection has announced a significant modernization of its refund process that will directly affect importers, customs brokers, and other members of the trade community. Beginning February 6, 2026, CBP will transition away from issuing paper refund checks and will instead require refunds to be processed electronically through the Automated Commercial Environment (ACE) Portal, absent a narrowly granted waiver.

According to CBP, this change follows recent upgrades to the ACE Secure Data Portal designed to streamline and automate refund enrollment. These enhancements introduce new online tools that allow refund recipients to securely authorize electronic payments and simplify the creation and management of importer accounts. CBP’s stated goal is to reduce processing delays, minimize errors, and improve security while aligning customs refunds with broader federal payment modernization initiatives.

The shift is not merely procedural. On February 6, 2026, the U.S. Department of the Treasury will stop issuing paper checks for CBP refunds altogether unless a recipient has obtained an approved waiver under Treasury regulations. Importers that have not completed electronic refund enrollment by that date risk delays—or potentially an inability to receive refunds—until enrollment issues are resolved. For companies accustomed to paper checks, this represents a meaningful operational change that should be addressed well in advance of the deadline.

CBP has emphasized that electronic refunds will offer faster payment timelines and enhanced protection against fraud and improper payments. From a compliance perspective, however, the transition also places increased responsibility on importers and brokers to ensure that ACE accounts are accurate, active, and properly linked to the correct entities. Errors in account setup, authorization, or banking information could delay refunds that may already be time-sensitive, particularly in cases involving protests, reliquidations, or court-ordered refunds.

This development is especially notable given the current environment of heightened tariff litigation and refund uncertainty. As importers pursue administrative or judicial remedies for unlawfully collected duties, the mechanics of how refunds are ultimately issued matter more than ever. Ensuring electronic refund readiness is now a critical part of preserving the practical value of any successful claim.

Importers should review their ACE Portal access, confirm that electronic refund authorization is complete, and coordinate with brokers and internal finance teams to ensure alignment well before the February 2026 cutoff. Companies that operate across multiple importer numbers or corporate entities should pay particular attention to whether each account is properly enrolled.

Our firm continues to advise clients on CBP procedures, refund strategy, and litigation-driven duty recovery. If you have questions about electronic refund enrollment, ACE account compliance, or how this change may affect pending or anticipated refund claims, we encourage you to contact us for guidance.