Tariff Refunds Are Moving: What Importers Should Know About ACE Access, Timing, and Treasury Disbursements

Current state of IEEPA refunds

For middle-market importers, tariff refund opportunities can represent meaningful cash recovery. As refund activity continues through U.S. Customs and Border Protection’s Automated Commercial Environment, commonly known as ACE, and CAPE functionality within it, companies should understand both the opportunity and the practical steps needed to manage the process.

The key message for executives is encouraging but measured: refunds are continuing to be processed and paid out, but the process may not be immediate, linear, or fully transparent at every stage. Companies that prepare early, monitor activity closely, and reconcile payments against entry-level data will be better positioned to understand what they have received and what may still be pending.

ACE access remains an important first step

Before companies can effectively manage certain tariff refund activity, they need appropriate ACE access.

Based on recent experience, importers should allow up to two weeks for ACE account approval. That timeline may vary, but it reinforces the importance of starting early. Companies that wait until they need to check refund status, review entry activity, or coordinate next steps may find themselves delayed by system access rather than the refund process itself.

Executives should confirm whether the company has an active ACE Portal account, whether the right internal users have access, and whether importer permissions are properly established. If the company relies heavily on its customs broker, it should still understand what visibility it has into its own importer records.

Refunds are being processed, but timing may vary

For importers waiting on refunds, one important update is that payments are continuing to be processed and disbursed. However, companies should not assume every expected refund will arrive all at once or that a single payment necessarily closes the process.

Recent activity suggests that certain disbursements may be issued in batches based on factors such as liquidation dates. For example, entries liquidated by a certain date may be included in one payment cycle, while later entries may be addressed separately.

That does not necessarily mean remaining amounts have been denied or lost. It may simply mean the refund activity is being processed in stages. Still, companies should monitor the status of expected refunds carefully.

Disbursements should be reconciled to entry-level data

When a Treasury disbursement is received, companies should compare the payment against the entries and the duty amounts they expected to recover. This is especially important for importers with large refund claims, multiple entries, multiple brokers, or complex product classifications.

A practical review should include entry numbers, liquidation dates, importer of record information, HTS classifications, country of origin, duty amounts paid, expected refund amounts, broker records, and any available ACE/CAPE activity. This information can help determine whether a payment appears to relate to a specific group of entries, a liquidation period, or a partial set of the company’s broader refund population.

Your goal is to understand what has been paid, what may still be pending, and whether any item requires follow-up.

Refund readiness requires coordination

Tariff refund management, when done effectively, is a widely coordinated effort. Finance teams need to understand the cash impact and timing, operations, and procurement teams may need to help connect entries to products, suppliers, and shipments.

Customs brokers can help retrieve entry data and explain how duties were paid or adjusted. Tax and accounting teams should consider how refunds should be recorded, particularly if duty costs were previously passed through to customers. This is a component that should not be overlooked.

Without clear ownership, a company may receive a payment but lack a defined process ensuring it aligns with the underlying entries and expectations.

What executives can do now

Companies pursuing tariff refunds should take several practical steps:

1. Confirm ACE access. Verify that the company has an active ACE Portal account, appropriate importer permissions, and the right internal users in place.
2. Allow time for approval. Build in up to two weeks for ACE account approval so access delays do not slow refund monitoring.
3. Track expected refunds. Maintain a schedule of entries, duty amounts paid, expected refund amounts, and liquidation dates.
4. Monitor disbursements. Compare Treasury payments against internal estimates, broker reports, and ACE/CAPE activity.
5. Coordinate follow-up. Work with brokers and advisors to determine whether any differences reflect timing, liquidation status, documentation, eligibility, or processing factors.

How we are helping manufacturers

Tariff refunds can provide meaningful cash recovery, but companies should treat the process as an active working capital opportunity rather than a passive administrative matter. Refunds are being paid, but timing, batching, and entry-level details can affect how and when companies receive expected amounts.

UHY works with middle-market importers to help evaluate tariff refund activity, review ACE/CAPE readiness, reconcile Treasury disbursements, and connect refund timing to broader cash flow and business planning. Companies that prepare now can move with greater clarity as refund activity continues.

Review Your Refund Readiness