Fewer than 10% of the 330,000 importers eligible for IEEPA refunds had completed ACH bank enrollment as of early March 2026 — weeks before CAPE even opened. New ACE Secure Data Portal account applications take up to a month to process. Apply today and you'll be filing late May. Wait two weeks and Phase 1 entries start aging out of the 80-day window. Section 122 expires July 24. The government's Federal Circuit appeal window closes around June 7. If you don't have ACE access, start now.
The Stat Nobody Is Repeating Loudly Enough
Fewer than 10% of eligible importers had completed ACH enrollment as of early March 2026. That means 90%+ of the 330,000 importers owed a piece of $166 billion had not set up the basic prerequisite to receive their money before CAPE opened on April 20.
Without ACH, CBP cannot pay you. The cleanest CAPE Declaration in the queue is worth zero with no bank account on file. CBP has issued no paper refund checks since February 6, 2026.
The Month-Long Delay Nobody Is Talking About
New ACE Secure Data Portal account applications take up to 30 days to process. This is not a five-minute signup. CBP runs identity verification, importer-of-record validation, and bond review before issuing portal access.
If you are an Importer of Record who has always filed through a customs broker, you may not have your own ACE account. Your broker has theirs. You have nothing. Without your own account, you cannot file a CAPE Declaration directly, you cannot enroll your own bank in ACH, and you cannot monitor your refund status via REV-615.
Apply via Form 5106 at ace.cbp.dhs.gov. Today, not next week.
What You Need Before You Can File
Four steps, in order. Skip any of them and the refund stops.
1. ACE Secure Data Portal account. Apply via Form 5106. Up to 30 days to process.
2. Importer sub-account inside ACE. Required to add bank info and access REV-615.
3. ACH bank enrollment. Add your US bank account details under the Importer sub-account. Manual setup. Does not auto-populate. CBP cannot send a refund without it.
4. CAPE Declaration. Upload the entry-number CSV through the CAPE tab in ACE.
If your customs broker handles your filings, your broker may have ACE access. But to monitor your own refund status through the REV-615 CAPE Refunds Trade Report, you need your own account.
New Clarifications From CBP
CBP has confirmed several mechanics that early sources got wrong:
- You CAN include both liquidated and unliquidated entries on the same CAPE Declaration. They don't need to be split.
- The voluntary reliquidation window is 80 days, not 90. Some early write-ups said 90; CBP's official page says 80.
- Once accepted, every Declaration receives a unique CAPE claim number. Track it.
- Unliquidated entries are scheduled to liquidate 45 days from Declaration acceptance.
- Already-liquidated entries within the 80-day window are reliquidated the next business day after acceptance.
- Refunds issue as one lump sum per Importer of Record per liquidation date — not entry by entry. Reconcile against your records, not against individual entry payments.
- Status is monitored via REV-615 CAPE Refunds Trade Report in ACE. That's the authoritative first-party signal.
The Math on Timing
Four scenarios. Pick yours.
1. File today (April 26): submitted into a congested portal, accepted in 1-2 weeks, 60-90 day processing, refund mid-July to mid-August.
2. Wait until May 15 to set up ACE: file late May, accepted early June, 60-90 days, refund August to September.
3. Apply for ACE today (takes a month): file late May, same August-September timeline as scenario 2 — but you started the clock now instead of waiting.
4. Miss the Phase 1 window entirely: wait for Phase 2 (no announced date) or file a formal protest under 19 U.S.C. § 1514.
Layer on the appeal risk: the government's Federal Circuit appeal window closes around June 7. A stay could pause refund processing for everyone still in the queue. Companies with accepted Declarations before any stay are likely protected. Companies waiting in validation are exposed.
The 90% Who Haven't Set Up ACH
If you haven't enrolled your bank account in ACE, you cannot receive your refund. Period.
CBP issues all IEEPA refunds electronically via ACH. No paper checks. No exceptions. No appeals process for missing ACH — the system pays the bank account on file or it does not pay at all.
The 90% of importers who skipped ACH enrollment in March are scrambling now. The portal queue is congested precisely because so many filers are setting up prerequisites at the same time they're trying to file.
Don't be one of them. ACH enrollment takes minutes once you're in ACE. Do it before you upload a single CAPE Declaration.
What to Do Right Now
Three actions. In order.
1. If you don't have an ACE account, apply today via Form 5106 at ace.cbp.dhs.gov. The 30-day clock starts when you apply, not when you remember to apply.
2. If you have an ACE account but no ACH enrollment, log in, navigate to your Importer sub-account, and manually add your US bank details. Do not skip this.
3. If your broker is filing CAPE for you, confirm two things: that they're actually filing CAPE Declarations (not all brokers are) and that your data is clean. The /find-a-customs-broker guide covers what to ask.
This is not a slow-moving government process you can catch up with later. Every day you wait is another day your refund sits in a queue behind importers who filed clean, fast, and early.
Key Takeaway
ACE Portal applications take up to 30 days. Fewer than 10% of eligible importers had ACH enrolled by early March. The Federal Circuit appeal window closes around June 7. Section 122 expires July 24. None of these dates wait for you. If you don't have an ACE account, apply today. If you have an account but no ACH, set it up before you read another word. If your broker isn't filing CAPE, find one who is.
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