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Duty drawback9 min read

Drawback accelerated payment: get paid in weeks, not years

How the 19 CFR 190.92 accelerated payment privilege and a 1A bond decide whether your drawback refund arrives in weeks or waits for liquidation.

PB

Parker Burr

CEO

October 13, 2026

What is accelerated payment, and why does it decide when you get paid?

Accelerated payment (AP) is a privilege CBP grants in advance that lets it pay your estimated drawback refund before the drawback entry liquidates. The regulation is blunt about what it is and is not: accelerated payment consists of the payment of estimated drawback before liquidation of the drawback entry, and accelerated payment of a claim does not constitute liquidation. Without the privilege, a filed claim simply sits in the queue until CBP liquidates it — which can take a year or more.

With AP approved, CBP's drawback FAQ says payment will usually occur within about three weeks of the AP acceptance date in ACE. That is CBP's stated expectation, not a guarantee, and the FAQ page carries no visible revision date. Getting there takes two things: a written privilege application to the drawback office where you file, and an active, sufficient activity code 1A bond on file in eBonds.

Key takeaways

  • →Filing a drawback claim is not the same as getting paid — without accelerated payment, the claim waits for liquidation.
  • →AP requires a written application under 19 CFR 190.92 plus a 1A drawback bond effective on or before the AP request date.
  • →A continuous 1A bond must equal 100% of estimated accelerated drawback for the bond term, with a $50,000 minimum.
  • →CBP says approved accelerated payments usually occur within about three weeks of AP acceptance in ACE; it is an expectation, not a promise.
  • →AP is revocable: noncompliant claims can be reduced, penalized under 19 CFR 190.62, or trigger revocation for good cause.

Filing the claim is not the finish line

The default path for a drawback claim is liquidation. Under 19 U.S.C. 1504(a)(2), a drawback claim not liquidated within one year of the date of claim is deemed liquidated at the amount asserted, unless the time is extended or suspended, and 19 CFR 190.81 mirrors that rule for claims meeting its conditions.

Treat that one-year clock as a ceiling, not a schedule. Courts have narrowed when deemed liquidation actually bites, and extensions and suspensions are common. For a finance team modeling cash, a claim without AP is an uncertain receivable with no reliable payment date.

Accelerated payment is also conditional on a clean file. CBP will approve it only where its review of the request finds no omissions from or inconsistencies with the drawback law and Part 190. And because AP is not a liquidation, CBP can still adjust the amount when the entry finally liquidates — if the final figure is lower, you repay the difference.

What goes in the 190.92 application

The application must be filed in writing with the drawback office where claims will be filed — it may be physically delivered or emailed. There is no online form that substitutes for it, though the drawback office will provide a sample letter format on request.

At minimum the letter must include your company name and address, IRS number with suffix, a description of the merchandise covered, the drawback provisions covered, and the estimated dollar value of potential drawback for the next 12-month period. That last number matters twice: it frames your request and it sizes your bond.

You also have to disclose whether you have previously been denied AP or had an approval revoked by any drawback office, submit a signed certification that statutory and regulatory requirements will be met, and describe — with sample documents — how you will ensure compliance. CBP publishes a combined privilege application covering one-time waiver of prior notice (190.36), waiver of prior notice (190.91), accelerated payment (190.92) and the drawback compliance program (190.193), which is the practical way to request more than one privilege at once.

We could not find a published CBP service level for approving a privilege application, so do not plan around a specific approval date. One timing note if you have something pending: CBP has consolidated drawback under the Petroleum, Natural Gas, and Minerals Center and, effective April 22, 2026, routes ACE drawback claims directly to the PNGM Center, while claims, privilege applications and ruling applications submitted before April 21, 2026 remain at the office where they were filed.

Bond math and the effective-date trap

Drawback claims generally do not require a bond. CBP's FAQ answer is essentially "no, except" — except where the claimant is preapproved for AP and requests it, in which case the accelerated payment must be secured by an active and sufficient 1A bond on file in eBonds.

The regulation puts the same obligation on the claimant: if approved for AP you must furnish a bond sufficient to cover the estimated drawback to be claimed during the bond term, and if outstanding accelerated claims exceed the bond, CBP requires additional coverage before further accelerated payments are made. The sizing rules come from CBP's bond guidance.

1A drawback bond sizing, per CBP's A Guide for the Public: How CBP Sets Bond Amounts (February 2024)
Bond typeAmountIncrements
Continuous 1A100% of estimated accelerated drawback for the bond term, $50,000 minimum$10,000 increments up to $100,000; $100,000 increments above that
Single transaction 1A100% of the AP to be received on the entry covered, $100 minimum—

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The effective-date trap

The 1A bond must have an effective date on or before the AP request date, and it is decremented when ACE accepts and pays the AP request. A bond that goes effective a day after you transmit the request does not save the claim — and once your outstanding accelerated claims consume the bond amount, further accelerated payments stop until you increase coverage. Size the bond to projected annual refunds, not to your first claim.

Already filed without AP? How to retrofit a claim

It is not automatically too late. Per CBP's guidance on AP bonding, claimants must ask the filing office to return the claim to trade control and then retransmit it with the AP request.

Eligibility for that retransmission still depends on the basics: approved AP privileges for the drawback provision you filed under, a valid and sufficient 1A bond, and compliance with all other requirements. If any of those are missing, the claim goes back in line for liquidation.

How importers lose the privilege

AP is revocable. In its drawback compliance reminders, CBP has warned that noncompliant claims will be liquidated without the benefit of drawback or reduced, that claimants may face penalties under 19 CFR 190.62, and that noncompliance may be "good cause" for revoking accelerated payment under 19 CFR 190.92(f).

The examples CBP gives are the ones growing importers trip over: claiming drawback on duties that were already refunded through another mechanism such as reconciliation, or claiming drawback on Section 232 duties. If you are unsure where Section 232 sits, we walk through it here.

Not every duty line is off limits. CBP stated that drawback is available with respect to the additional duties imposed under the February 20, 2026 Section 122 proclamation; secondary trade coverage of that CSMS reports the duty applied to entries between February 24, 2026 and July 24, 2026. That is a fresh layer of drawback-eligible duty for importers who export.

The other two privileges change filing, not payment speed

Waiver of prior notice and one-time waiver are often bundled into the same application as AP, which causes confusion about what each one does. Neither accelerates payment; they govern whether you can export without giving CBP advance notice.

Under 19 CFR 190.35, CBP Form 7553 must be filed at least five working days before the intended exportation unless CBP approves another period or waiver of prior notice is granted, and CBP responds within two working days with its decision to examine or waive examination. Approval of waiver of prior notice operates prospectively — it applies only to exports or destructions after the date of the waiver, which is why the separate one-time waiver exists for past exports.

Frequently asked questions

How long does a duty drawback claim take to get paid?

It depends entirely on whether you hold the accelerated payment privilege. CBP's drawback FAQ says an approved accelerated payment will usually occur within about three weeks of the AP acceptance date in ACE. Without AP, the claim waits for liquidation, and 19 U.S.C. 1504(a)(2) allows up to a year before deemed liquidation — longer if the time is extended or suspended.

Do I need a bond to file a drawback claim?

Generally no. CBP's FAQ says a bond is not required except where the claimant is preapproved for accelerated payment and requests it, in which case the AP must be secured by an active and sufficient activity code 1A bond on file in eBonds. So the bond is the price of speed, not the price of filing.

How big does a drawback bond need to be?

A continuous 1A bond must equal 100% of the estimated accelerated drawback for the bond term, with a $50,000 minimum, set in $10,000 increments up to $100,000 and $100,000 increments above that. A single transaction 1A bond must equal 100% of the accelerated payment to be received on the entry covered, with a $100 minimum. If outstanding accelerated claims exceed the bond, CBP requires additional coverage before paying further accelerated claims.

Can I request accelerated payment on a claim I already filed?

Possibly. CBP's guidance says the claimant must ask the filing office to return the claim to trade control and then retransmit it with the AP request. You still need approved AP privileges for the drawback provision, a valid and sufficient 1A bond, and compliance with all other requirements.

Can CBP take back an accelerated payment?

Yes. Accelerated payment is not a liquidation, so CBP can adjust the amount when the drawback entry liquidates, and the bond secures repayment. CBP has also warned that noncompliance may constitute good cause to revoke the AP privilege under 19 CFR 190.92(f), alongside reduced claims and penalties under 19 CFR 190.62.

What to do next

If you are preparing your first claim, apply for accelerated payment and arrange the 1A bond before you transmit anything. Use your realistic 12-month refund estimate to size the bond, and confirm with your surety that the effective date lands on or before the date you will request AP.

If you already have claims sitting unpaid, check two things: whether your AP privilege covers the specific drawback provision you filed under, and whether your bond still has room after earlier accelerated claims decremented it. Those two checks explain most "why hasn't CBP paid us" questions.

Evana handles the privilege application, bond sizing and claim filing as part of duty drawback recovery, with fees contingent on what you actually recover. If you want the cost side first, start with what duty drawback actually costs.

Sources

  1. 1.19 CFR 190.92 — Accelerated payment · eCFR
  2. 2.19 CFR 190.92 Accelerated payment (full text) · Cornell Legal Information Institute
  3. 3.19 CFR 190.91 — Waiver of prior notice of intent to export or destroy · Cornell Legal Information Institute
  4. 4.19 CFR 190.35 — Notice of intent to export or destroy · eCFR
  5. 5.19 CFR 190.81 — Liquidation · eCFR
  6. 6.19 U.S.C. 1504 — Limitation on liquidation · FindLaw
  7. 7.Drawback — ACE Frequently Asked Questions · U.S. Customs and Border Protection
  8. 8.TFTEA Combined Privilege Application · U.S. Customs and Border Protection
  9. 9.CSMS #48631253 — Accelerated Payment Continuous Bonding Policy Programming Update · U.S. Customs and Border Protection
  10. 10.CSMS #61941423 — Drawback Compliance Reminders · U.S. Customs and Border Protection
  11. 11.CSMS #68577428 — Drawback Transition to the PNGM Center · U.S. Customs and Border Protection
  12. 12.CSMS #67844987 — Imposing Temporary Section 122 Duties · U.S. Customs and Border Protection
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