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Tariff Reconciliation and Reimbursement: What AR and O2C Teams Need to Do Now

Clear Cycle Advisors

How your company billed tariff costs in 2025 determines your legal and operational exposure today. If you separately itemized surcharges rather than embedding them in price, customers have a basis to claim reimbursement from you, and that awareness is spreading quickly through the buyer community.

The Supreme Court’s February 2026 ruling invalidating IEEPA tariffs created two problems for finance operations teams. The first is a government refund your company may be entitled to claim. The second is a customer base that believes they absorbed tariff costs that the government is now refunding to you, and that perception is already generating relationship friction.

Deductions Are Already Starting

Volume will grow as CAPE (Consolidated Administration and Processing of Entries) refund processing matures and customers become more aware of their recoupment rights under price-adjustment, surcharge pass-through, and change-in-law provisions.

Most AR dispute workflows were not designed for this because standard deduction management assumes the dispute is about a specific invoice, typically a pricing error, a short shipment, or a promotional allowance. Tariff deductions are different because they reference a period of time, a category of spend, and a contractual theory that collections staff are likely not equipped to evaluate. Routing them through the standard dispute queue will produce increased write-off pressure and resolution backlogs.

A dedicated tariff deduction workflow needs four components:

  1. A triage filter that identifies and separates tariff-related deductions from standard disputes at the point of entry.
  2. A documentation requirement where the customer must provide invoice numbers, surcharge amounts, and the contractual basis for their claim.
  3. An escalation path that routes validated claims to someone who can review contract language, not collections staff focused on delinquency and DSO targets.
  4. Defined resolution criteria so your team knows which claims to settle, which to dispute, and which to escalate further.

Without this infrastructure, you will write off legitimate disputes or settle illegitimate ones.

Two Cash Flows With No Playbook

You are sitting between an inbound cash flow from CBP, a government refund processed through the CAPE portal and paid via ACH on CBP’s timeline, and an outbound obligation to customers seeking credit against open invoices or future purchases. The amounts, timing, and accounting treatment are all unsettled, and your team will be asked to reconcile it anyway.

Here’s what that can look like in practicve. A customer deducts $18,000 from a current invoice, citing tariff surcharges billed across fourteen invoices between March and August 2025. Your CBP refund for that same period, when it arrives, may cover a broader set of imported goods across multiple customers and will not be itemized by customer relationship. The reconciliation problem is that nobody in your organization has mapped one to the other.

For each customer relationship where tariff surcharges were billed, determine the total amount invoiced, what the customer has claimed or deducted, and what portion of the CBP refund is attributable to that customer’s purchases. That mapping does not require the accounting question to be settled. It requires someone to pull the data and build the picture before the volume arrives.

In my experience, the organizations that manage this well are not waiting for guidance from Legal or Finance before touching the AR file. They are building the exposure map now, which gives leadership the information it needs to make decisions before external pressure forces them into making decisions without the right level of level of data.

The Practitioner Advantage

Legal is reviewing contract language and Finance is working through the accounting model, but neither function has visibility into the customer ledger the way AR and O2C practitioners do. That puts the O2C team in the best position to resolve disputes before they escalate.

AR and O2C teams that move now should start by pulling 2025 surcharge billing data, mapping it to open customer relationships, and identifying where exposure is concentrated. That work surfaces the information finance leadership needs before external pressure forces the decision.

Set Up the Infrastructure Now

Five things AR and O2C leaders should be doing right now:

  1. Audit your 2025 invoices to determine how tariff costs were billed and to whom.
  2. Build a tariff deduction triage workflow before volume forces a reactive response.
  3. Map customer-level surcharge exposure against your expected CBP refund.
  4. Align with Legal and Finance on resolution criteria before your collections team starts making settlement decisions.
  5. Document how costs were billed, what customers were told, and how disputes are being resolved.

The companies that build this infrastructure now will spend less time and money resolving disputes than those that wait.

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