PSC Duty Increases: How to Pay by ACH Before ACE Locks the Entry

A duty increase on a PSC used to be a payment question. Since the August 5 change it is also a question of whether the entry can still be corrected next month. For a compliance manager at a large multinational importer reviewing a few hundred PSCs a quarter across several brokers, one unpaid increase can quietly freeze an entry that later needs a second fix, including one that would have lowered the duty.

GingerControl builds GingerOS, an AI trade compliance platform that checks each entry's HTS code, country of origin and customs value. It does not file PSCs, pay duty or act for the importer of record; the importer or its licensed broker does.

What changed about PSC payments, and when did it take effect?

CBP runs PSCs as a National Customs Automation Program test under 19 CFR 101.9(b), which lets CBP set test rules by Federal Register notice instead of by regulation ^[1]. On July 6, 2026, CBP published 91 FR 41053, FR Doc. 2026-13574, which republished the whole PSC test with three changes and one clarification ^[2]. CBP announced it to the trade in CSMS # 69428352 on August 3, 2026 ^[3].

The notice states the first change directly:

"test participants must transmit electronic payment of an increase in estimated duties, taxes, and fees resulting from a PSC via Automated Clearinghouse (ACH) starting on August 5, 2026 and will no longer be able to pay such increases via check or cash."

The changes, in one place:

Bottom line: For a trade operations lead who signs off broker PSCs, the rule that changes daily work is the lock, not the payment rail. What is new is that an unpaid increase now closes the entry to further PSCs, so the payment choice has to be made at filing, with the next correction in mind.

The test runs until CBP concludes it by another Federal Register notice. AD/CVD increases follow a stricter rule: the notice requires ACH payment of additional AD/CVD within three business days of submitting the PSC, and the pay-now-or-wait choice does not apply to them ^[2].

When can you file a PSC at all?

A PSC is a complete replacement of the entry summary filed through ABI before liquidation. It does not replace the date of entry or the date of entry summary, and obligations that already vested, such as liquidated damages for a late summary, survive it ^[2].

The entry or previous PSC must meet all of these, per the notice and CBP's PSC page (last modified August 6, 2026) ^[4]:

1. Not liquidated. CBP's page states that once an entry is liquidated, "the filers options to correct the entry summary is to file a prior disclosure or a protest."
2. Fully paid and in CBP control. An entry is in CBP control when it is placed on a statement.
3. Accepted, and not under CBP review. ACE returns "PSC not allowed under CBP Review" otherwise.
4. Not associated with a protest, and if flagged for reconciliation, the PSC cannot touch the flagged issue. The guide to customs reconciliation entry flagging covers that split.
5. Inside the window: "within 300 days of the date of entry or up to 15 days prior to the scheduled liquidation date, whichever date is earlier." With an extension of liquidation granted under 19 CFR 159.12, the PSC must be filed at least 15 days before the scheduled liquidation date ^[5].

The window is tight because CBP's PSC page refers to a 314-day liquidation cycle, and an entry not liquidated within one year is deemed liquidated under 19 CFR 159.11 ^[6]. The notice adds that when a PSC has been properly filed, deemed liquidation happens at the duty asserted in the most recently accepted PSC. The guide on how to check entry liquidation status shows where to read the scheduled date in ACE.

One more constraint matters for periodic monthly statement (PMS) importers. CBP's PSC page says: "If the entry summary is on a Periodic Monthly Statement (PMS), the entry must be 'truly' paid in order for the PSC to be accepted. It may be up to 45 days following the entry date before CBP receives payment for the statement." The PMS field itself is on the list of data a PSC cannot change ^[4].

Do you pay at submission or wait for the bill at liquidation?

Either is allowed. CSMS 69428352 puts it this way: "The filer must remit payment in full for increases in additional duties, taxes, and fees resulting from a PSC at the time of PSC submission or wait until CBP issues a bill reflecting the full amount of the increase at the time of liquidation. Partial payment of increased duties, taxes, and fees resulting from a PSC will not be accepted."

The two paths cost different amounts and leave the entry in different states.

Bottom line: For a CFO office weighing cash timing against control, waiting buys several months of float on the increase and costs interest for the same months, plus the loss of every later PSC on that entry. Paying at submission is the default that keeps options open; waiting is defensible only on an entry the team is confident will need no further correction.

How interest works on a PSC increase

Interest on underpaid duty is statutory. Under 19 U.S.C. 1505(c), it accrues "from the date the importer of record is required to deposit estimated duties, fees, and interest to the date of liquidation or reliquidation" ^[7]. 19 CFR 24.3a(b)(2)(i)(B)(1) sets the rule for a pre-liquidation deposit that turns out to be correct: interest runs on that amount "only from the date of the initial deposit until the date the additional deposit was made" ^[8].

The regulation's own example: an importer deposits $1,000 on January 1, makes an additional deposit of $200 on May 1, and the entry liquidates for $1,200 on December 1. The importer is billed interest on $200 for January 1 to May 1, four months. Had the $200 waited for the liquidation bill, interest would have run to December 1, eleven months.

The notice adds the operational rule: "Interest payments on a PSC made before liquidation will not be accepted." The importer pays interest once CBP liquidates and issues a bill. Bills are due within 30 days of issue under 19 CFR 24.3(e), and an unpaid balance becomes delinquent and bears further interest under 19 U.S.C. 1505(d) ^[9].

What happens if you file a PSC, do not pay, and then need another?

ACE refuses the second PSC. The notice is explicit: "Test participants will not be able to file a subsequent PSC until the increase in estimated duties, taxes, and fees resulting from the previously filed PSC is paid in full and processed by CBP." CSMS 69428352 restates it as a system behavior: "Should a filer choose to wait for billing at liquidation, ACE will not allow the filer to file subsequent PSCs until the initial PSC is paid."

Quotable insight: Under the August 2026 PSC rules, an unpaid increase does more than defer cash. It freezes the entry against every later correction, including one that would lower the duty. In a hypothetical case, a team that waits for the liquidation bill on a $5,000 classification increase, then finds a valuation error worth $8,000 in its favor on the same entry, cannot file the second PSC until the first is paid in full. If the 300-day window closes first, the refund route moves to a protest after liquidation.

The practical fix is a short sequence: pay the outstanding increase in full through ACH, wait for CBP to process it, then file the next PSC while the window is still open. Each step takes days, and the window closes 15 days before scheduled liquidation, so the lock matters most on entries close to the 300-day mark. A PSC that CBP rejects can be retransmitted within two business days; after that, the notice says CBP will correct the entry summary itself and set it for immediate liquidation ^[2].

How do you enroll in ACH Debit or ACH Credit before you need it?

Enrollment comes first, and it is not instant. Per CBP's ACH page ^[10]:

• ACH Debit. File CBP Form 400. The filer transmits a payment authorization through ABI, and CSMS 69428352 says the account is debited usually two business days after CBP accepts it. The filer must file entries through ABI using statement processing, and the bank must be a U.S. NACHA participant with EDI capability. CBP says new applications "can take up to 15 business days from the date of receipt." CBP assigns a Payer Unit Number, and an importer's designated broker can use that number to pay only that importer's statements.
• ACH Credit. File CBP Form 401. The filer initiates the payment from its own bank in CCD+ or CTX format with the TXP addendum. CSMS 69428352 says the transaction must originate at least one day before the settlement date, cannot be reversed once started, and is reconciled manually by CBP if the amount does not match.

Statement processing under 19 CFR 24.25 already names ACH as the preferred method for statement payments, and it bars mixing methods on one statement ^[11]. Before the first PSC increase, settle two questions: which party's Payer Unit Number pays PSC increases when several brokers file for one importer of record, and whether finance knows a debit is coming.

When is a PSC the right instrument, and when do you need prior disclosure instead?

The deciding facts are liquidation status and penalty exposure. A PSC is a correction tool, not a penalty shield. CBP's ACE Entry Summary Business Rules and Process document (Version 12.0, December 2023) states that "a participant amending entries under the test procedures will be subject to the usual penalties, liquidated damages, and other administrative sanctions for any Customs law violations," and that "filers that excessively use PSC's may be penalized for failing to exercise reasonable care" ^[12].

Prior disclosure under 19 CFR 162.74 is made by disclosing the circumstances of a violation of 19 U.S.C. 1592 before, or without knowledge of, a formal investigation, and tendering the actual loss of duties ^[13]. Under 19 U.S.C. 1592(c)(4), a valid prior disclosure for negligence or gross negligence caps the penalty at interest on the lost duty, provided the duty is tendered ^[14].

Bottom line: For a compliance manager who finds the same misclassification on 40 entries, the PSC is the mechanical fix for the unliquidated ones, but it does not answer the penalty question for the pattern. That question goes to counsel before the PSCs go out, because a disclosure made with knowledge of a formal investigation does not qualify under 162.74. The prior disclosure guide covers the 162.74 mechanics.

Can a PSC that decreases duty be a recovery route?

Yes, and for unliquidated entries it is the cleanest one. A PSC that lowers duty replaces the entry summary, the entry liquidates at the corrected amount, and under 19 U.S.C. 1505(b) CBP must refund "any excess moneys deposited, together with interest thereon," within 30 days of liquidation ^[7]. Interest on the excess runs from the date of deposit to liquidation under 1505(c).

Three points decide how well it works:

1. Speed. CBP's PSC page says a filer can request accelerated liquidation on a PSC, and "CBP will strive to process within 60 calendar days from the date it was received." Without it, the refund waits for the normal cycle.
2. The lock applies. A decrease PSC cannot be filed while an earlier PSC increase on the same entry is unpaid.
3. Not for everything. The trade agreement (19 U.S.C. 1520(d)) indicator for specific special programs cannot be changed by PSC, and IEEPA refunds run on their own rules; the CAPE vs protest vs PSC decision guide routes those entries. For liquidated entries the route is a protest; see how to file a customs protest.

GingerControl identifies and documents the opportunity; your licensed broker or counsel files.

How do you catch duty increases before the entry liquidates?

The earlier an error is found, the cheaper it is: more of the PSC window left, fewer days of interest, and no lock pressure. Three habits do most of the work:

• Review on a fixed day after entry, not at month end. A review at day 30 to 60 leaves room for a second PSC if the first one surfaces another issue.
• Decide the payment path in the PSC procedure. Write "pay in full by ACH at submission" as the default in the broker instructions, with named exceptions approved by finance.
• Track open PSC increases by entry. Any entry with an unpaid increase should appear on a list with its scheduled liquidation date, because it cannot take another correction.

GingerOS checks each entry's HTS code, country of origin and customs value. GingerControl's trade advisory practitioners act as a second pair of eyes on classification and CBP requests, and also work on prior disclosure; it is not legal advice, and GingerControl is not the importer of record and does not file entries.

References

1. Electronic Code of Federal Regulations, 19 CFR 101.9, Test programs or procedures; alternate requirements
   Data cited: NCAP tests under 101.9(b) may impose requirements different from the CBP Regulations, by Federal Register notice
   Source: 19 CFR 101.9
2. U.S. Customs and Border Protection, "Modification and Clarification of the National Customs Automation Program Test Regarding Post-Summary Corrections," 91 FR 41053, FR Doc. 2026-13574
   Data cited: ACH-only payment of PSC increases from August 5, 2026; pay in full before liquidation or wait for the bill; subsequent PSC blocked until paid; interest not accepted before liquidation; AD/CVD increases within three business days; 300-day and 15-day window; suspended-entry exception; two-business-day retransmission; deemed liquidation at the latest accepted PSC
   Source: 91 FR 41053, Federal Register
   Published: July 6, 2026
3. U.S. Customs and Border Protection, CSMS # 69428352, Modifications to the Processing of Post Summary Corrections
   Data cited: ACH requirement effective August 5, 2026; ACH Debit and ACH Credit process; full payment or bill at liquidation; ACE blocks subsequent PSCs until paid; interest billed after liquidation
   Source: CSMS # 69428352
   Published: August 3, 2026
4. U.S. Customs and Border Protection, Post Summary Correction
   Data cited: PSC criteria; liquidated entries corrected by prior disclosure or protest; PMS entries must be truly paid, up to 45 days; data that cannot be changed; 314-day liquidation cycle; accelerated liquidation within 60 days
   Source: CBP Post Summary Correction
   Last modified: August 6, 2026
5. Electronic Code of Federal Regulations, 19 CFR 159.12, Extension of time for liquidation
   Data cited: extension of the one-year liquidation period on the importer's written request for good cause
   Source: 19 CFR 159.12
6. Electronic Code of Federal Regulations, 19 CFR 159.11, Entries liquidated by operation of law
   Data cited: entry not liquidated within one year of entry is deemed liquidated
   Source: 19 CFR 159.11
7. 19 U.S.C. 1505, Payment of duties and fees
   Data cited: collection of increased duties and refund of excess deposits with interest on liquidation; refunds within 30 days of liquidation; interest accrual period
   Source: 19 U.S.C. 1505, govinfo
8. Electronic Code of Federal Regulations, 19 CFR 24.3a, CBP bills; interest assessment on bills
   Data cited: interest on a correct additional pre-liquidation deposit runs only from the initial deposit to the additional deposit; $1,000 and $200 worked example
   Source: 19 CFR 24.3a
9. Electronic Code of Federal Regulations, 19 CFR 24.3, Bills and accounts; receipts
   Data cited: bills for duties, taxes, fees and interest due within 30 days of issuance
   Source: 19 CFR 24.3
10. U.S. Customs and Border Protection, Automated Clearinghouse (ACH)
    Data cited: ACH Debit via CBP Form 400, statement processing and NACHA bank requirement, up to 15 business days for new applications, Payer Unit Number; ACH Credit via CBP Form 401, CCD+ or CTX with TXP addendum
    Source: CBP Automated Clearinghouse
11. Electronic Code of Federal Regulations, 19 CFR 24.25, Statement processing and Automated Clearinghouse
    Data cited: ACH debit or credit as preferred statement payment; no mixing of payment methods on one statement
    Source: 19 CFR 24.25
12. U.S. Customs and Border Protection, ACE Entry Summary Business Rules and Process, Version 12.0
    Data cited: PSC participants subject to usual penalties and sanctions; excessive PSC use may show lack of reasonable care
    Source: CBP ACE Entry Summary Business Rules and Process
    Published: December 2023
13. Electronic Code of Federal Regulations, 19 CFR 162.74, Prior disclosure
    Data cited: disclosure before or without knowledge of a formal investigation, with tender of actual loss of duties
    Source: 19 CFR 162.74
14. 19 U.S.C. 1592, Penalties for fraud, gross negligence, and negligence
    Data cited: prior disclosure caps the negligence or gross negligence penalty at interest on the lost duty, with tender
    Source: 19 U.S.C. 1592, govinfo