What happened with IEEPA tariff refund claims after April 20, 2026?

Phase 1 IEEPA tariff refund claims had an initial CBP filing deadline of April 20. Firms that filed are now in the CBP review queue — processing expected to take 60–120 days. Firms that missed the deadline are not necessarily out of options: CBP has indicated it may accept late-filed Phase 1 claims on a case-by-case basis through mid-2026. Phase 2 (goods imported after the pause extension) has no confirmed deadline yet. Firms with unfiled Phase 1 claims should consult customs counsel now.

What happened to IEEPA tariffs and why are refunds available?

In Learning Resources v. Trump (decided February 20, 2026), the Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA) as exceeding the President's statutory authority. As a result, duties paid on imports covered by those tariffs are now refundable. CBP (Customs and Border Protection) is managing the refund process through a new system called CAPE (Customs Automated Payment Engine), which launches April 20, 2026. Importers who paid IEEPA-based tariffs are eligible to file claims — but must register in the CAPE system by the April 20 deadline.

How much is at stake in IEEPA tariff refunds?

CBP estimates over $166 billion in eligible tariff refunds across 330,000+ importers. As of late March 2026, only approximately 8% of eligible importers had registered for the CAPE system. The gap between eligible claimants and registered claimants represents a significant advisory opportunity for accounting firms: many of your importer clients have not taken the necessary steps to protect their refund rights.

What is the April 20 deadline and what happens if you miss it?

April 20, 2026 is the CAPE system launch date and the registration deadline for Phase 1 of the refund process. Phase 1 covers unliquidated entries (entries still pending final duty assessment) and entries liquidated within the 80-day period following the Supreme Court ruling. Missing the April 20 registration deadline means claims for entries in this phase are rejected — there is no known extension or late-registration option. Subsequent phases may have different deadlines; confirm with CBP guidance as it is released.

What do accounting firms need to do to help importer clients with IEEPA refunds?

Three steps: (1) Identify importer clients — look for freight charges, import duties, or customs fees on their financial statements; many business owners don't identify themselves as 'importers' even when they are. (2) Confirm ACE portal enrollment — the Automated Commercial Environment portal enrollment must be current with active ACH banking details to receive refunds. Check this before April 20. (3) Help organize entry data — entry numbers, entry dates, ports of entry, and duty amounts paid. CBP will need this documentation for claim processing. This is not technical customs law — it is financial documentation that accountants are well-positioned to help gather.

IEEPA Tariff Refund Accounting Firms 2026

Published April 18, 2026 · Updated September 2026 · By The Crossing Report · 6 min read

Summary

Supreme Court struck down IEEPA tariffs in Learning Resources v. Trump (February 20, 2026) — duties paid on covered imports are now refundable
CBP's CAPE refund system launches April 20, 2026 — missing the registration deadline means Phase 1 claims are rejected
Over $166 billion in eligible refunds across 330,000+ importers; only 8% had registered as of late March 2026
Three steps for accounting firms: identify importer clients, confirm ACE portal enrollment, help organize entry documentation

What Happened and Where Things Stand Now

On February 20, 2026, the Supreme Court issued its ruling in Learning Resources v. Trump: tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceed the President's statutory authority. Every importer that paid duties under IEEPA tariff orders has a legal right to a refund.

CBP managed the refund process through CAPE (Customs Automated Payment Engine). Phase 1 — covering unliquidated entries and entries liquidated within 80 days of the ruling — had a registration deadline of April 20, 2026.

For firms that filed by April 20: Your importer clients are now in CBP's review queue. Processing is expected to take 60–120 days from the filing date. No further action is needed unless CBP requests additional documentation.

For firms that missed the April 20 deadline: Don't assume the window is permanently closed. CBP has indicated it may accept late-filed Phase 1 claims on a case-by-case basis through mid-2026. Clients with unfiled claims should consult their customs counsel now — not at year-end.

Phase 2 (goods imported after the pause extension): No confirmed deadline has been announced. Monitor CBP guidance and advise affected clients to maintain organized entry documentation in the meantime.

Who Is Eligible

IEEPA tariff refunds apply to importers who paid duties under tariff orders issued under IEEPA authority. This covers a wider range of businesses than the term "importer" typically suggests in common usage.

Directly eligible:

Manufacturing companies that import raw materials or components
Retailers and distributors that import finished goods for resale
Businesses that import equipment, technology hardware, or industrial supplies

Often overlooked:

Professional services firms that import technology hardware (server equipment, specialized devices)
Construction companies that import materials from covered countries
Restaurants and food businesses importing food products from covered geographies

The practical test: does the business pay customs duties anywhere on its financial statements? Freight line items sometimes embed duty costs. Many business owners who don't identify as "importers" have paid IEEPA tariffs and are eligible for refunds.

Three Steps Accounting Firms Should Still Take

Step 1: Identify Your Importer Clients

Go through your client list and look for freight charges, import duties, customs fees, or international supply chain costs on their financial statements. These are the clients with potential IEEPA tariff refund eligibility.

Do not rely on clients self-identifying as importers — many businesses that pay customs duties think of themselves as retailers, distributors, or manufacturers, not importers. The financial statement is the authoritative source.

For any client with customs duty payments in 2024 or 2025, verify whether they filed a Phase 1 CAPE claim. If they didn't, flag them for customs counsel review — late filing may still be possible on a case-by-case basis.

Step 2: Confirm ACE Portal Enrollment and Banking Details

The ACE (Automated Commercial Environment) portal is CBP's primary system for importer registration and document submission. To receive refunds through CAPE, an importer must:

Be enrolled in ACE with an active Importer of Record number
Have current, accurate ACH banking details on file in ACE

Many importers have ACE enrollments from years ago with outdated banking information. An importer who registered in ACE in 2018 and changed banks since then will not receive refund payments unless they update their ACH details before the refund processing begins.

Accounting firm action: Help your importer clients log into the ACE portal, confirm enrollment status, and update banking details. This is not a technical customs filing — it is a straightforward administrative step that most business owners can complete in 15–30 minutes with guidance.

Step 3: Help Organize Entry Documentation

CAPE will require documentation to process claims. The key data points:

Entry numbers — the CBP-assigned number for each import entry (on the CBP Form 7501 or equivalent)
Entry dates — when each import entry was filed
Ports of entry — where each shipment entered the US
Duty amounts — the tariff duties paid on each entry

This documentation is typically held by the importer's customs broker and appears in summary form on the CBP Form 7501. Accounting firms can help clients gather and organize this data, verify it against financial records, and prepare it in the format CAPE will require.

The Advisory Conversation to Have Now

Whether your importer clients filed by April 20 or not, the conversation your firm has with them in the next 30 days matters.

If they filed: Reassure them that processing will take 60–120 days. Tell them to keep their ACE portal banking details current so CBP can deposit refunds without delay. Ask them to flag any CBP documentation requests to you immediately.

If they missed the deadline: Do not assume the window is closed. Call their customs broker this week to assess late-filing options under CBP's case-by-case review process. Help them organize entry documentation now so they are ready if CBP opens a window.

For Phase 2 (post-extension imports): No deadline is confirmed yet. The firms that have entry documentation organized and customs broker relationships current will move fastest when CBP announces the Phase 2 process.

This is not a technical customs advisory — accounting firms should not provide customs law opinions or file customs entries. The role is: identify the exposure, advise the client to engage their customs broker, and help gather the financial documentation that process will require.

The firms that followed up after April 20 — not just the ones that filed in April — will be the advisors those clients remember.

AI Tariff Advisory for Accounting and Consulting Firms — Comprehensive guide to building tariff advisory services with AI workflow support
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AI Bookkeeping and Pricing Strategy for Accounting Firms — How AI changes accounting firm economics and pricing

Sources

Learning Resources v. Trump, Supreme Court, February 20, 2026
CBP: CAPE (Customs Automated Payment Engine) system announcement and documentation, April 2026
CBP: IEEPA tariff refund eligibility guidance, March–April 2026

The Crossing Report covers the AI transition for professional services firm owners. The premium tier includes an IEEPA tariff refund client outreach kit — talking points, ACE enrollment checklist, and entry documentation request template. Subscribe here →

IEEPA Tariff Refund Opportunities for Accounting Firms April 2026