ACE reconciliation: Entry Type 09 Flags, Deadlines and Filing

Key Points

• ACE reconciliation lets an importer flag an entry summary for value, classification, 9802 or FTA issues it cannot finalize, then close them later with a reconciliation entry type 09.
• Deadlines per CBP's reconciliation page: FTA flags are due 12 months from the oldest entry's importation date; value, classification or 9802 flags are due 21 months from the oldest entry summary date.
• The program requires a reconciliation bond rider, and 81 FR 89486 (December 12, 2016) moved reconciliation into ACE with importer-applied blanket flags.
• As of September 2026, ACE reconciliation is still an ACE prototype under the NCAP test in 19 CFR 101.9(b), not a permanent regulation; confirm current status before acting.
• A flagged issue is closed through the type 09 entry, not through a PSC (post summary correction) or a protest.

On this page

1. At a glance
2. What is ACE reconciliation and where does it come from?
3. Who is responsible for ACE reconciliation and when does it happen?
4. How is an ACE reconciliation entry filed?
5. Common ACE reconciliation errors
6. How ACE reconciliation relates to other ACE functions
7. Frequently asked questions
8. What importers and brokers should do
9. Key references

ACE reconciliation is the ACE program under which an importer flags an entry summary at filing for issues it cannot yet finalize (value, classification, 9802 or FTA claims) and later files a reconciliation entry, entry type 09, that closes those issues and pays or claims the duty difference. Importers decide what to flag, customs brokers transmit the flags and the later type 09 entry, and the process runs from entry summary through to a reconciliation filing made within fixed deadlines. It is neither a post summary correction nor a protest.

At a glance

ACE reconciliation, as of October 2026, can be summarized in the following fields.

• Full name: ACE Reconciliation (reconciliation entry type 09)
• Who prepares or uses it: The importer decides on flags; the customs broker or filer transmits flags and the type 09 entry
• When in the lifecycle: Flag at entry summary; reconciliation entry filed later, within the 12-month (FTA) or 21-month (value, classification, 9802) window
• System or channel: ACE via ABI; confirm transaction details in the ACE CATAIR
• Governing authority: NCAP test under 19 CFR 101.9(b); 81 FR 89486; 85 FR 39576 for USMCA flags under 19 U.S.C. 1520(d)
• Bond: Reconciliation bond rider required
• Related terms: PSC, ACE protest module, DIS, CATAIR Appendix B, ACE Reports Modernized

The links in this article go to the primary documents: the Federal Register notices, regulations, statutes, and official CBP and tariff schedule pages themselves. Read the source.

What is ACE reconciliation and where does it come from?

ACE reconciliation exists because some entry elements cannot be known with certainty when the entry summary is filed, and CBP allows the importer to declare them provisionally and settle them later. Typical reconcilable issues include transfer-price adjustments that change the transaction value, assists not yet quantified, costs relevant to HTS heading 9802 treatment, classification questions awaiting a ruling, and post-importation USMCA claims.

Legal basis and status

CBP runs ACE reconciliation as a National Customs Automation Program test under 19 CFR 101.9(b). The Federal Register notice at 81 FR 89486, published December 12, 2016, announced reconciliation in ACE, introduced importer-applied blanket flags, and set the reconciliation bond rider requirement. The notice at 85 FR 39576, published July 1, 2020, addressed USMCA flags for post-importation claims under 19 U.S.C. 1520(d). Both notices can be retrieved by citation at federalregister.gov. As of September 2026, ACE reconciliation is still an ACE prototype (NCAP test), not a permanent regulation; confirm the current status with CBP before relying on it.

Who is responsible for ACE reconciliation and when does it happen?

ACE reconciliation is the importer's decision and liability, while the broker or filer carries out the electronic transmissions on the importer's behalf.

At entry summary

The importer decides which issues to flag and whether to flag blanket (across its entries) or entry by entry. The broker transmits the reconciliation flag and the issue code with the entry summary. Valid flag and issue code values should be confirmed in the ACE CATAIR rather than assumed. Before flagging, the importer secures a reconciliation bond rider on its continuous bond.

At reconciliation

Within the deadline, the filer submits the reconciliation entry type 09 with an association file listing the underlying flagged entries and the adjustments to each, then pays the additional duty or claims the refund. Per CBP's reconciliation page, the windows are:

• FTA flags: 12 months from the importation date of the oldest entry covered.
• Value, classification or 9802 flags: 21 months from the oldest entry summary date covered.

The two clocks start from different events, so track importation date and entry summary date separately for each flagged entry.

How is an ACE reconciliation entry filed?

ACE reconciliation filings move through ABI into ACE, with the type 09 entry and its association file transmitted electronically rather than on paper. The association file ties each flagged entry to the reconciliation and carries the line-level adjustments. Record layouts, issue codes and response messages are defined in the ACE CATAIR on CBP's ACE pages, and the entry type code itself appears in CATAIR Appendix B (Valid Codes), the ABI appendix listing code values such as entry types and fee codes. Supporting documents CBP requests can typically be sent through DIS (Document Image System), CBP's ACE channel for transmitting electronic images tied to an entry; see our DIS guide. Confirm specific supporting-document expectations with CBP.

Common ACE reconciliation errors

ACE reconciliation errors usually come from flagging decisions made casually at entry and then forgotten until the deadline.

• Blanket flags with no reconcilable issue: Flagging everything by default creates obligations to reconcile entries that never needed it.
• Missed deadlines: If the 12-month or 21-month window passes, the flagged issue liquidates unreconciled and the opportunity to adjust through reconciliation is lost.
• PSC used on the flagged issue: A PSC (post summary correction) is the wrong vehicle for an issue already flagged for reconciliation; the flagged element belongs in the type 09 entry.
• No rider on the bond: Flagging without a reconciliation bond rider in place creates a bond sufficiency problem; confirm rider status before the first flagged entry.
• Swapped clocks: Applying the 21-month period to an FTA flag, or measuring from the wrong date, puts the filing out of time.

How ACE reconciliation relates to other ACE functions

ACE reconciliation sits at the end of the entry chain, after cargo has moved and entry summaries have been filed, so most other ACE functions feed it data rather than overlap with it.

• Upstream movement: ACE truck eManifest (ACE e-Manifest: Trucks, the carrier's pre-arrival manifest), ACE in-bond (the electronic in-bond system for moving unentered goods under bond) and ACE Cargo Release (the release transaction that succeeded the paper CBP Form 3461) all occur before the entry summary and are not changed by a reconciliation flag.
• Duty data: ACE AD/CVD case management publishes Commerce's antidumping and countervailing duty case numbers and rates keyed on entry lines; whether any AD/CVD element can be addressed through reconciliation should be confirmed with CBP.
• Disputes: The ACE protest module, used to file the electronic CBP Form 19 under 19 U.S.C. 1514 and 19 CFR part 174, handles disputes over CBP decisions, which is a different purpose from closing flagged issues. See our ACE protest module guide.
• Tracking flagged entries: ACE Reports Modernized, the rebuilt ACE Reports platform, can help identify flagged entries and their dates. Importers auditing older broker filings sometimes use ITRAC (Importer Trade Activity) data obtained under the Freedom of Information Act; see our ITRAC article. Report access depends on account users that the Trade Account Owner or a proxy TAO (the ACE Trade Account Owner proxy who manages users and permissions) sets up.

Frequently asked questions

Is ACE reconciliation the same as a post summary correction?

No. ACE reconciliation closes issues flagged at entry summary through a type 09 entry, while a PSC corrects an unflagged entry summary; using a PSC on a flagged issue is a recognized error.

What are the ACE reconciliation deadlines?

Per CBP's reconciliation page, ACE reconciliation of FTA flags is due 12 months from the oldest entry's importation date, and value, classification or 9802 flags are due 21 months from the oldest entry summary date.

Is ACE reconciliation a permanent program?

As of September 2026, ACE reconciliation is still an ACE prototype operating as an NCAP test under 19 CFR 101.9(b), not a permanent regulation. Confirm current status with CBP before acting.

Do I need a special bond for ACE reconciliation?

Yes. ACE reconciliation requires a reconciliation bond rider, as set out in 81 FR 89486; confirm the rider is active with your surety before flagging.

What importers and brokers should do

• Flag only issues that are genuinely undeterminable at entry summary, and document the reason for each blanket or entry-by-entry flag.
• Confirm the reconciliation bond rider is in place before the first flagged entry is transmitted.
• Build a calendar that tracks the 12-month FTA clock from importation date and the 21-month value, classification and 9802 clock from entry summary date.
• Route flagged issues only to the type 09 entry, and confirm issue codes and association file layouts in the current ACE CATAIR.

Key references

• 19 CFR 101.9(b): authority for NCAP tests, under which ACE reconciliation operates.
• 19 U.S.C. 1520(d): statutory basis for post-importation preferential claims such as USMCA.
• Federal Register, 81 FR 89486 (December 12, 2016): ACE reconciliation, importer-applied blanket flags and the reconciliation bond rider; search by citation.
• Federal Register, 85 FR 39576 (July 1, 2020): USMCA 1520(d) flags in reconciliation; search by citation.
• CBP ACE pages: ACE CATAIR, including CATAIR Appendix B, and CBP's reconciliation guidance and deadlines.
• Harmonized Tariff Schedule: official text of heading 9802 and other provisions relevant to flagged issues.