Following the U.S. Supreme Court’s invalidation of the Trump administration’s tariff program under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection (CBP) has moved quickly to operationalize what may become one of the largest tariff refund processes in recent history.

On April 20, 2026, CBP launched new functionality in the Automated Commercial Environment (ACE) Portal, through the Consolidated Administration and Processing of Entries (CAPE) framework, to support the submission and administration of valid IEEPA tariff refund claims. In CSMS #68536553, CBP also confirmed that Automated Clearing House (ACH) refund payments could begin issuing as early as May 12, 2026, although some media reports suggest that certain importers may already be receiving refunds. Importers should therefore rely primarily on CAPE status updates and official CBP communications to track the timing and status of their own refund claims.

Securing refunds, however, may be more complex than simply waiting for payments. CBP has indicated that millions of entries are moving through CAPE validation, and that significant numbers of claims are being delayed, diverted, or rejected due to reporting discrepancies, ACH enrollment issues, and data mismatches. Importers should act promptly to implement robust internal refund-monitoring procedures and to actively leverage ACE reporting tools to help ensure accurate, timely processing of their refund claims.

CAPE and ACE: CBP’s New Refund Infrastructure

CBP’s CAPE functionality was designed to centralize and streamline the administration of IEEPA refund claims arising from the Supreme Court’s invalidation of the tariff program. To support that effort, CBP has deployed several new ACE reporting tools that allow importers to monitor refund claims throughout the refund lifecycle.

ES-022 CAPE Entry Summary Report

The ES-022 report links CAPE declaration numbers, entry summaries, refund claim identifiers, and refund payment information. The report also separately identifies principal and interest amounts associated with approved refunds, allowing importers to reconcile expected recovery values against accounting records.

REV-603 Trade Refund Report

The REV-603 report tracks refund claims through various “Refund Secondary Status” categories, including: (i) “Sent to Treasury”; (ii) “Treasury Issued”; (iii) “Funds Diverted”; and (iv) “Check/ACH Returned.” This report may prove especially important for identifying refunds that encounter processing interruptions after initial approval.

REV-613 ACH Rejected Refunds Report

The REV-613 report identifies refund claims rejected because of ACH enrollment deficiencies or incomplete banking information. CBP has specifically emphasized that importers should confirm ACH enrollment information is accurate and current to avoid unnecessary refund delays.

REV-615 CAPE Details Refunds Report

The REV-615 report provides entry-summary-level detail for CAPE declarations transmitted to Treasury for payment processing and may assist importers in reconciling individual refund claims against specific entries and declarations.

Importers Should Expect Administrative Friction

Although CBP has publicly emphasized efforts to streamline refunds, importers should anticipate operational challenges given the unprecedented volume of claims moving through the system.

CBP has indicated that:

• Millions of entries have already undergone CAPE validation review;  
• Substantial numbers of claims have moved into active refund processing;  
• Certain entries have been rejected for validation or documentation issues; and  
• Other refunds have stalled because of ACH enrollment problems or Treasury transmission complications.  

In addition, CBP has encouraged importers to establish recurring ACE report scheduling to receive automated email delivery of refund information and reduce processing delays associated with manual report retrieval. CBP has also highlighted the usefulness of ACE data fields (including CF 4811 notify party identifiers) for identifying parties connected to particular refund claims and entries.

Practical Steps Importers Should Be Taking Now

Given the scale and complexity of the refund process, importers should consider taking several immediate operational steps.

Confirm ACE and ACH Readiness

Importers should: (i) verify ACE Portal access remains active; (ii) confirm user permissions are current; (iii) validate ACH refund enrollment information; and (iv) coordinate with customs brokers, finance teams, and third-party administrators to ensure refund reporting responsibilities are clearly assigned.

Regularly Review ACE Refund Reports

Companies should establish recurring monitoring procedures for:

• ES-022 reports;  
• REV-603 reports;  
• REV-613 reports; and  
• REV-615 reports.  

Prompt review may allow companies to identify rejected, diverted, or delayed refunds before additional processing complications arise.

Preserve Refund Documentation

Importers should maintain entry summaries, payment records, CAPE declarations, reconciliation documentation, broker communications, and internal accounting support materials. Given the size of anticipated refunds and the likelihood of future audits or reconciliations, strong recordkeeping practices will be critical.

Coordinate Refund and Tariff-Litigation Strategies

Many companies simultaneously face ongoing Section 122 tariff exposure, possible future Section 301 tariffs, and pending refund opportunities tied to invalidated IEEPA duties. Importers should therefore evaluate refund administration, tariff mitigation, and litigation strategies together rather than treating them as isolated compliance issues.

The Emerging Secondary Market

A secondary market for IEEPA tariff refund rights and related receivables is developing quickly. Because many refund claims are large and payment timing remains uncertain, some importers are exploring ways to assign, sell, pledge, or otherwise monetize anticipated refunds with lenders, funds, and specialty receivables buyers. These transactions are not simple receivable sales. They implicate the federal Assignment of Claims Act, CBP and Treasury payment procedures, UCC perfection and priority, bankruptcy (including after‑acquired property and 11 U.S.C. § 552), contractual allocation between importers and their customers, customs broker authority, and basic questions about when the refund claim becomes a property interest that can be transferred or pledged. Parties also need to consider whether rights remain with the importer of record, how Treasury offsets or other government claims may reduce recoveries, and how CAPE and ACE will treat any purported assignments or participations.

Public reporting suggests that a secondary market of up to roughly $100 billion in potential refund claims is emerging. Hedge funds and private credit funds are reported to be buying interests in claims from importers, with pricing moving from about $0.20 on the dollar before the Supreme Court decision to the $0.50–$0.90 range afterward. Other reports describe term loans secured by refund claims, with payment‑in‑kind interest, loan‑to‑value ratios around 50%, and minimum loan sizes of about $10 million backed by claims roughly twice that amount. Some trades reportedly involve claims in the tens of millions to more than $100 million. These figures are drawn from press accounts and should be treated as indicative only; actual structures and terms are transaction‑specific.

Even with Phase 1 ACH payments beginning to hit bank accounts, a substantial volume of IEEPA refund exposure remains tied up in CAPE validation and in entries expected to be addressed in later CAPE phases, including entries under protest or currently excluded from Phase 1. Market participants also need to account for the risk that further appellate activity by the U.S. government, including any appeal or stay affecting the refund framework, could slow or suspend payments and change the economics of these trades. The government has until June 7, 2026, to appeal the CIT’s nationwide IEEPA refund order, and any appeal is expected to challenge the CIT’s authority to mandate refunds nationwide. As more CAPE declarations are processed and additional phases come online, the use of refund monetization and structured recovery deals is likely to grow, particularly among companies that need liquidity rather than waiting for CBP processing or appeals. For lenders, borrowers, and claims purchasers, the key point is that these are legally constrained transactions. Any sale or financing of IEEPA refund rights should be structured with close attention to the Assignment of Claims Act, UCC perfection and priority, existing credit agreements and customer contracts, and the practical limits of CBP and Treasury systems in recognizing third‑party interests in the refunds.

Refund Opportunities Are Significant — But So Are the Risks

For many importers, the invalidation of the IEEPA tariffs presents an opportunity to recover substantial duty payments. But the scale of the refund process also creates meaningful operational and compliance risks.

Companies that fail to actively monitor ACE reporting, maintain accurate ACH information, or promptly address rejected claims may face significant delays in recovering funds.

As CBP continues implementing the CAPE framework and processing refund activity, importers should remain closely engaged with customs counsel, brokers, and internal compliance teams to ensure refund claims are properly tracked, reconciled, and preserved.