U.S. Customs and Border Protection (CBP)plans to launch on Mondaya claims portal to handle tariff refunds related to a recent court ruling, with the total potential refunds estimatedat approximately $166 billion。

Finance leaders are expected to play a central role in guiding their organizations through this process, with success depending on document quality, cross-functional coordination, and how companies account for any final refunds.

According to Bryan Graiff, who leads the manufacturing and distribution practice at accounting and consulting firm Armanino, the effort is reminiscent of pandemic-era relief programs such as the Paycheck Protection Program and the Employee Retention Credit, where CFOs served as the final checkpoint for compliance, accuracy, and financial reporting.

"While other teams may collect the data, the CFO is ultimately responsible for ensuring its accuracy and determining the appropriate accounting treatment," Graiff said in an interview.

The U.S. Court of International Traderuled last monththat tariffs overturned by the U.S. Supreme Court in February must be refunded. Graiff said the trade community remains uneasy about the possibility of a government appeal.

Despite the uncertainty, Graiff said companies should not wait for final clarity before taking action.

"We are advising clients to prepare for the opportunity to obtain refunds because we believe this will be a very complex process requiring a lot of preparation," he said.

According to Nghi Huynh, head of Armanino's transfer pricing practice, CBP's recent efforts give companies good reason to believe a viable refund process is taking shape.

"There is definitely positive momentum," she noted, pointing to CBP's plan to launch its portal on Monday.

Phased process

CBP is expected to roll out in phases, with the agency estimating that about 63% of refunds will be processed in the initial phase, which focuses on certain unliquidated entries and entries liquidated within 80 days.

As of April 9, approximately 56,497 importers had completed the steps to receive electronic refunds, involving about $127 billion in duties, CBP said in a filing Tuesday with the U.S. Court of International Tradestated。

"Monday's change is the launch of the claims portal itself," Huynh said. "That is when importers can begin formally submitting refund applications and supporting documents, which will allow CBP to start reviewing and processing these requests."

In Tuesday's filing, CBP provided an update on its "Consolidated Entry Merge and Processing" (CAPE) program used to handle refund applications, stating the agency has completed "major development of all components and functionality for CAPE Phase 1."

"The agency has transitioned to an intensive testing phase, focusing on performance and scenario-based testing of all CAPE components, and fixing any defects identified during testing," CBP official Brandon Lord wrote in the filing.

Documentation hurdles

The refund process is expected to require extensive documentation, including importer record filings, as well as detailed information on the contents of goods and duties paid, according to Graiff.

Companies may also need to demonstrate whether tariff costs were absorbed internally or passed on to customers through pricing decisions, down to the product or stock-keeping unit (SKU) level. For large shipments containing thousands of SKUs, complexity can escalate quickly, Graiff said.

For tariff-affected companies that deprioritized record-keeping while scrambling to secure inventory, the process could be especially challenging.

"I can imagine that in the rush to get these products, some of the paperwork may not always have been filled out 100% accurately," he said.

Beyond ensuring documentation is complete, CFOs should also prepare by assessing the potential "downstream impact" of receiving refunds, such as financial reporting and tax-related issues, Huynh said.

"For some companies, this could be a fairly significant amount," she said.

Graiff said close coordination between CFOs and other teams is critical, especially with supply chain and procurement leaders who are closest to the underlying transactions and supplier relationships.

"They will be key to compiling the necessary documents, while the CFO helps ensure all inputs are consistent, accurate, and ready for submission," he said.