Last reviewed: October 6, 2026. Reading time: about 9 minutes.
Given the size of this program, roughly $166 billion, 330,000 importers, 53 million entries, it is reasonable to wonder whether the money is actually moving or whether this is mostly paperwork and promises. The answer is in the public record. CBP does not just announce progress through press releases; it certifies specific numbers to a federal court, under its own name, on a recurring basis. That is a meaningfully higher bar than a marketing claim.
This guide walks through that evidence directly: what CBP has told the Court of International Trade, what independent law and accounting firms are reporting to their own clients, and where real friction still exists, so you can judge the program on facts rather than on a headline.
The short version: yes, refunds are happening. As of CBP’s September 15, 2026 declaration to the Court of International Trade, over 201,000 CAPE declarations had been accepted, covering 27.2 million entries, with approximately $122 billion already certified and transmitted to the U.S. Treasury. CAPE Phase 3 deployed on schedule on October 6, 2026. The program has real friction points too, covered honestly below, but the core claim that money is moving is well documented.
Transparency note: this guide is educational. At the end, we link to a referral partner and may earn a commission if you apply through that link. Read our affiliate disclosure and disclaimer.
In this guide
Evidence 1: CBP's own sworn court filings
Declarations filed directly with a federal court
CBP does not report its IEEPA refund progress through press releases alone. It files formal declarations with the U.S. Court of International Trade, in ongoing litigation, under the name of a specific CBP official, Brandon Lord, Executive Director of Trade Programs. These filings are part of the court record, in a case where opposing parties and the court itself can scrutinize the numbers. This is a materially different standard of evidence than a company simply announcing good news.
Evidence 2: the hard numbers
From CBP’s September 15, 2026 declaration, with data current as of September 11:
That $122 billion figure is not a promise or a projection. “Certified and transmitted to Treasury” describes money that has completed CBP’s internal approval process and moved toward actual payment. By comparison, an earlier CBP update to the court on May 12, 2026 reported about $35.46 billion in confirmed refunds and interest, which means the certified total has grown substantially in the months since, further evidence of an active, moving process rather than a stalled one.
Evidence 3: independent professional confirmation
Major law and accounting firms are actively advising on real filings
This is not a niche topic being covered only by interested parties. National law firms including Thompson Hine, Norton Rose Fulbright and White and Williams, and accounting firms including BDO and Cherry Bekaert, have published detailed client alerts walking through CAPE mechanics, deadlines and filing requirements. These firms are advising real corporate clients on real filings. If the underlying refund process were not functioning, this volume of professional, client-facing guidance would not exist.
Evidence 4: a track record of hitting dates
A program that only existed on paper would likely slip its own deadlines repeatedly. CAPE has instead hit a series of specific, dated milestones in sequence:
CAPE Phase 1 deploys as announced, opening filing for unliquidated and recently liquidated entries.
CBP's first detailed court update reports roughly $35.46 billion in confirmed refunds.
CAPE expands to accept certain reconciliation-flagged entries, on schedule.
The Court of International Trade orders CBP to reliquidate certain finally liquidated entries.
CBP's declaration confirms $122 billion certified and transmitted, and announces the Phase 3 date.
CAPE Phase 3 deploys exactly as CBP told the court it would.
This article is being published on the day Phase 3 launched, exactly as CBP committed to the court three weeks earlier. That kind of consistency between stated plans and actual deployment is itself a form of evidence.
What has not gone smoothly
A fair evidence review includes the parts that have not worked cleanly. None of these contradict the core finding that refunds are happening, but they are real and worth knowing.
- About $1.3 billion in approved refunds had not been transmitted as of the September 15 declaration, specifically because valid ACH banking details were missing, a logistics gap, not a sign the money does not exist.
- Millions of entries failed validation at the file or entry level, mostly due to filer mismatches, formatting errors or excluded entry types, covered in our mistakes guide, rather than CBP declining to pay.
- Congress has pressed CBP directly on delays, with members writing on September 9, 2026 about importers struggling to get ACE accounts approved within relevant windows.
- Phase 3 is narrower than many expected, covering only plaintiffs with a specific court reliquidation order, not every importer with finally liquidated entries, detailed in our Phase 3 guide.
- Carrier-cleared shipments have drawn lawsuits over how promptly refunds are passed through from couriers to the customers who originally paid.
How to verify it for yourself
The strongest evidence is your own entry showing a status change. If you have filed a CAPE Declaration, check your own Claim Status directly in the ACE Portal rather than relying on secondhand reports, using our status guide. That is the most direct confirmation available to any individual importer.
Evidence of a real program is not a guarantee for your specific entries. The numbers above confirm the system is functioning at scale. They do not confirm your own eligibility, amount or timeline, which depend entirely on your individual entries. See our scams guide for how to tell a legitimate inquiry about your own claim from a fraudulent one.
Frequently asked questions
Yes. CBP's September 15, 2026 declaration to the Court of International Trade reports approximately $122 billion already certified and transmitted to the U.S. Treasury, a figure filed under CBP's own name as part of an active federal court case.
CBP's declarations are filed with the Court of International Trade and are frequently summarized by law and accounting firms such as Thompson Hine, Cherry Bekaert and BDO in their public client alerts, several of which are linked in the sources below.
CAPE has hit its major announced dates, including Phase 1 on April 20, 2026, the reconciliation expansion on June 29, 2026, and Phase 3 on October 6, 2026, as stated in advance to the court.
Program-level progress does not guarantee individual timing. Reasons for a delay on your specific entries include missing ACH details, entry-level exclusions, or simply still being within CBP's normal 60 to 90 day processing window. Check your own status directly rather than assuming.
They reflect friction in how some carriers are passing refunds through to their customers, a separate issue from whether CBP itself is processing and paying refunds, which the court filings confirm independently.
Multiple law firms describe it as the largest refund effort in CBP's history, based on the scale CBP itself has represented to the court, approximately $166 billion across 330,000 importers and 53 million entries.
See where your own claim stands
The program-level evidence is strong, but the only number that matters to you is your own. Tariff Refund Agency offers a free eligibility check that takes about five minutes, with no commitment.
Start Your Free Eligibility Check
Affiliate disclosure: if you apply through this button, we may earn a commission from Tariff Refund Agency. Refund eligibility, amounts and timing depend on individual circumstances and are never guaranteed. Read our affiliate disclosure and disclaimer.
Sources and further reading
- Tariff Refunds Finder: IEEPA Tariff Refund: Are You Owed Money by CBP?
- Tariff Refunds Finder: How to Check Your IEEPA Tariff Refund Status (CAPE Guide)
- Tariff Refunds Finder: IEEPA Phase 3 Refunds, What Later-Stage Claimants Must Know
- CBP: IEEPA Duty Refunds (official page)
- Thompson Hine: CBP Confirms October 6, 2026 Launch of Phase 3
- Corporate INTL: What Is the Status of IEEPA Refunds? CAPE Phase 3 Explained
Educational only. Tariff Refunds Finder is not CBP, U.S. Customs or a government agency, and this guide is not legal or financial advice. Figures reflect CBP's public court filings as of October 6, 2026 and may change as the program continues.
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