CBP's Sept 15 CIT declaration (figures as of Sept 11): $134.7B accepted and $122B certified. Phase 3 launches October 6, 2026 for CIT plaintiffs only. The step-by-step timeline below is unchanged; the status section is new. Check CAPE refund status →
The Supreme Court struck down IEEPA tariffs on February 20, 2026. The first refund payments arrived in importer bank accounts on May 12, 2026 — 81 days later. That gap isn't bureaucratic delay; it's the operational sequence of getting from a constitutional ruling to ACH refunds across 330,000-plus importers and 53 million-plus entries. This guide walks through every step on that timeline: what happened when, the 45-day liquidation cadence that drives CBP's internal workflow, how CAPE acceptance translates to a refund check, how statutory interest is calculated, and what status transitions inside the CAPE portal tell you about where your money is. For importers still waiting, the timeline is also a planning tool — you can predict roughly when your refund will arrive based on when your CAPE Declaration was accepted.
Where IEEPA Refunds Stand in September 2026
The timeline below still explains the path from the February 20, 2026 ruling to an ACH deposit. The dollar picture has moved since the first checks on May 12.
CBP's September 15, 2026 declaration to the Court of International Trade (figures as of September 11) reported $134.7 billion accepted for CAPE processing (27.2 million entries) and $122 billion certified to Treasury — about 73% of the ~$166 billion IEEPA pool. Phases 1 and 2 are live. Phase 3 for finally liquidated entries is confirmed for October 6, 2026, and only for importers who are plaintiffs in a pending CIT case and who submitted their IOR number by July 30, 2026.
Two different jobs:
- You have not filed. Start with how to claim an IEEPA refund and the tariff-refunds hub. Only the Importer of Record (or the broker who filed the entries) can file. This is not a consumer check, and nothing here is a guaranteed dollar amount.
- You already filed. Check status in ACE via the REV-615 report. The plain-English version is on CAPE refund status. CBP's working window is still 60–90 days from acceptance to ACH, plus statutory interest under 19 CFR 24.36.
There is an active scam wave around "tariff refund" checks and a supposed consumer dividend. No consumer tariff dividend has been approved by Congress. CBP does not email or text a claim link.
The Sequence of Key Dates
The full IEEPA refund timeline from court to bank account:
- April 2, 2025 — Trump invokes IEEPA to impose reciprocal tariffs (the duties that became refundable).
- May 28, 2025 — CIT rules IEEPA tariffs unlawful in V.O.S. Selections v. Trump.
- June 10, 2025 — Federal Circuit grants administrative stay; tariff collection continues.
- August 29, 2025 — Federal Circuit, sitting en banc, affirms the CIT ruling 7-4.
- February 20, 2026 — Supreme Court strikes down IEEPA tariffs 6-3 in *Learning Resources v. Trump*.
- February 24, 2026 — Trump invokes Section 122 to impose a 10% global tariff for 150 days as a replacement.
- March 4, 2026 — CIT orders CBP to refund all 330,000+ importers (~$166B across 53M+ entries) — not just plaintiffs.
- April 20, 2026 — CBP launches CAPE Phase 1 in the ACE Portal.
- May 12, 2026 — First ACH refund payments hit importer bank accounts.
From SCOTUS to first refund check: 81 days. From the nationwide refund order to first check: 69 days. From CAPE launch to first check: 22 days. Those three intervals are the practical timeline most importers care about.
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Why Refunds Don't Arrive Instantly
Two things drive the operational delay between a court ruling and an ACH deposit:
1. The 45-day liquidation cadence. CBP processes entries through liquidation on a structured schedule — most entries liquidate automatically 314 days after entry summary date under 19 U.S.C. § 1504, but operationally CBP works on 45-day liquidation batches. CAPE Declarations are processed against these batches: a Declaration submitted today doesn't get reviewed until the next batch cycle, which typically falls 15-45 days after submission depending on timing.
2. ACH refund mechanics. Once a CAPE Declaration is accepted, the refund moves through CBP's Treasury settlement system. The agency batches refunds and posts them to ACH for transmission to the importer's bank account on file. Standard ACH cycles run 2-3 business days from CBP-side settlement to bank deposit. CBP's working internal target is 60-90 days from CAPE Declaration acceptance to ACH deposit, including the liquidation review cycle and Treasury settlement.
For entries with clean data and ACH already enrolled, the 60-day end of that window is typical. For entries that hit rejection-and-resubmit cycles, the 90-day end is more realistic — and resubmission can push beyond 90 days if multiple rounds are needed.
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ACH Refund Mechanics
Every CAPE refund is paid via ACH to the bank account enrolled in the importer's ACE Portal Importer sub-account. There is no paper check option. ACH enrollment must happen before the CAPE Declaration is submitted — Declarations submitted before ACH is enrolled are accepted but held until enrollment is complete.
The practical sequence:
- CAPE Declaration accepted in ACE (status: "Accepted").
- CBP review and liquidation reconciliation — internal step, typically 30-60 days.
- Refund authorization issued (status: "Refund Authorized").
- Treasury settlement and ACH transmission — 2-3 business days.
- Funds deposited to the bank account on file in ACE.
One important operational note: the refund hits the bank account on file at the time of acceptance, not the time of submission. If your ACH enrollment changes between submission and acceptance, the refund routes to the old account. Update ACH carefully and only between filing cycles.
Statutory Interest
All IEEPA refunds carry statutory interest under 19 U.S.C. § 1505(c). Interest accrues from the date the original duty was paid to the date the refund is settled.
The applicable rate is the Treasury underpayment rate set quarterly under 26 U.S.C. § 6621 — currently in the 5-7% APR range, varying by quarter. CBP calculates interest automatically inside CAPE and includes it in the refund payment; importers don't claim it separately.
A typical example: $100,000 IEEPA duty paid on a Vietnam entry in June 2025, refund settled in July 2026. The duty accrued interest for 13 months at an average ~6% APR, adding roughly $6,500 to the refund. For a $1,000,000 IEEPA duty payment on the same timeline, the interest add is roughly $65,000.
For importers with meaningful exposure, the interest layer is a real factor — it's pure float compensation, paid by Treasury, and does not reduce based on broker fees or refund-help engagement.
How to Track Your Refund in CAPE
Inside the CAPE module of the ACE Portal, every Declaration moves through a defined status sequence:
Status transitions a typical clean Declaration goes through:
- Submitted — Declaration filed; awaiting initial review (typically same day).
- Accepted — initial data validation passed; CBP queue assigned (typically 1-5 business days from submission).
- Updated — CBP has reconciled the Declaration against the original entry; refund amount confirmed and locked (typically 15-45 days from acceptance).
- Refund Authorized — Treasury settlement initiated (typically 5-15 days from "Updated").
- Paid — ACH transmission complete; funds in importer's bank account (typically 2-3 business days from "Refund Authorized").
Status transitions for rejected Declarations:
- Submitted → Rejected — initial data validation failed; specific error code returned. Submitter must resolve and resubmit.
- Submitted → Accepted → Held — initial data validation passed but reconciliation flagged a discrepancy. CBP requests additional documentation; Declaration paused until resolved.
The status report inside CAPE shows the last status change date for every Declaration, which is the operational signal for where you are in the timeline. A Declaration sitting at "Accepted" for more than 45 days is unusual and worth investigating — typically a reconciliation hold that hasn't been flagged. The CAPE help desk inside ACE responds to status-related inquiries on most Declarations within 5 business days.
Estimate Your Refund Before You File
If you haven't already estimated what your refund should look like, do that before submitting a CAPE Declaration — it sets your expectation for the dollar amount and the interest layer, and it tells you whether the refund warrants a pre-filing data audit. A 60-second estimator returns a country-specific estimate and emails the full breakdown within 5 minutes. For refunds over $100,000, the breakdown is the input you'd use to decide whether to engage a trade attorney or file in-house through your existing broker.
Key Takeaway
From the February 20, 2026 SCOTUS ruling to the first ACH refund on May 12, 2026 was 81 days — driven by the March 4 CIT nationwide order, the April 20 CAPE launch, and CBP's 45-day liquidation cadence. CBP's working target for individual refunds is 60-90 days from CAPE Declaration acceptance to ACH deposit, with statutory interest at the Treasury underpayment rate (~5-7% APR) included automatically. Inside CAPE, the status sequence is Submitted → Accepted → Updated → Refund Authorized → Paid; the date of the last status change tells you where you are in the timeline. For importers still waiting, the operational checklist is straightforward: confirm ACE access and ACH enrollment before submission, file the Declaration as soon as the 80-day window opens on liquidated entries, monitor status weekly, and resolve any rejection errors inside 5 business days to avoid resubmission delays.
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