Donald Trump Says Tariff Dividend Checks Could Be Issued Mid-2026: What Trade Teams Need to Know

As of mid-February 2026, US Customs and Border Protection reported roughly $175 billion collected from tariffs imposed under emergency authority before the Supreme Court struck them down.

For US importers, exporters, and customs brokers, this unprecedented accumulation of duties has been the defining operational challenge of the past year. Now, the legal foundation for those collections has collapsed, creating a chaotic environment of mass refunds and replacement tariffs. Yet, the administration's political messaging remains unchanged. Donald Trump says tariff dividend checks could be issued mid-2026, redistributing these funds to American households.

However, following the landmark Supreme Court ruling on February 20, the mechanics of achieving this have grown exceedingly complex. Donald Trump proposes tariff dividends could arrive by 2026, but trade professionals must navigate a reality where the original funding source is legally slated for return to the importers who paid it. This briefing breaks down the post-ruling policy landscape, the mechanics of impending refunds, the impact of new Section 122 tariffs, and the practical steps trade professionals must take right now.

What Trump Has Said Since the Supreme Court Ruling

The trade environment shifted dramatically on February 20, 2026. In the case of Learning Resources, Inc. v. Trump, the US The Supreme Court ruled 6-3 that the executive branch overstepped its statutory authority under the International Emergency Economic Powers Act (IEEPA) by imposing broad, sweeping economic tariffs.

This ruling effectively invalidated the duties that were intended to fund the administration’s domestic stimulus plan. However, in press briefings immediately following the decision, the administration doubled down on its domestic promises. The president insisted that the $2,000 checks are still coming, suggesting that executive authority alone might be sufficient to disburse funds without formal Congressional appropriation.

Simultaneously, the administration executed an immediate pivot to replace the lost revenue. Within hours of the Court’s decision, the president signed an executive order invoking Section 122 of the Trade Act of 1974. This statute, designed to address severe balance-of-payments deficits, was used to impose a new, immediate 15% global tariff on imported goods. .

Independent budget analysts highlight a severe disconnect between the administration's goals and fiscal reality. The Tax Foundation notes that sending $2,000 to eligible US households would cost upwards of $400 billion to $600 billion. With the original $175 billion now legally vulnerable to refund claims, the funding mechanism for the dividend checks remains highly speculative as of late February 2026.

How Tariff Revenue, Refunds, and Section 122 Actually Work

To understand the likelihood of a mid-2026 dividend versus a mass refund, compliance professionals must understand the mechanics of tariff collection and the jurisdiction of the U.S. Court of International Trade (CIT).

Tariffs are paid by the US Importer of Record at the time goods enter the US commerce stream. When a US customs broker files an entry, US Customs and Border Protection (CBP) collects the standard duties plus any emergency tariffs, depositing them directly into the US Treasury’s general fund. 

Because the Supreme Court deemed the IEEPA collections illegal, the government cannot simply reallocate that $175 billion to citizen dividend checks. While the Supreme Court has ruled that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) in 2025-2026 are unlawful, the process of obtaining refunds is currently a legal battleground, not an automatic guarantee. Importers are not automatically entitled to funds without action. They must file formal protests within 180 days of liquidation or join existing lawsuits in the Court of International Trade (CIT) to preserve their rights.

Senate Democrats have introduced the "Tariff Refund Act of 2026" (co-sponsored by 22 senators) to compel CBP to refund the estimated $175 billion in IEEPA duties within 180 days with interest. A similar "RELIEF Act" has been proposed in the House. This legislation faces a tough path in a divided Congress. Additionally, the Trump administration has indicated it may fight the refund process, with some officials suggesting it could take years to litigate. CBP may legally offset refunds against other outstanding debts or liabilities the importer owes the government.

Meanwhile, the new 15% tariff under Section 122 operates under a different statutory framework. Section 122 allows the president to impose temporary import surcharges to correct a balance-of-payments deficit. While this provides a new legal shield for the administration, trade lawyers are already preparing challenges, arguing that the current macroeconomic indicators do not meet the statutory requirements of the 1974 Trade Act.

What Mid-2026 Could Actually Look Like

Given the chaotic legal and legislative variables, trade teams must plan for multiple, overlapping outcomes. Below are three potential realities for mid-2026 and how they will impact cross-border operations.

Scenario 1: 

The Administrative Bottleneck (Most Likely): In this scenario, CBP is overwhelmed by hundreds of thousands of refund requests for the invalidated IEEPA tariffs. The agency moves slowly, heavily scrutinizing every commercial invoice and entry summary (CBP Form 7501). Simultaneously, CBP rigorously enforces the new 15% Section 122 tariffs. Importers face a severe cash flow crunch: they are paying new, high tariffs daily while waiting months for their legal refunds to process. The dividend checks stall in Congress due to a lack of available Treasury funds.

Scenario 2: 

The Executive Standoff: The administration aggressively attempts to delay or block IEEPA refunds, arguing that the funds are necessary to issue the promised dividend checks. This triggers an avalanche of litigation at the US Court of International Trade. Importers are forced to seek federal injunctions to force CBP to release their money. The compliance burden shifts heavily to legal teams, and supply chain predictability drops to zero.

Scenario 3: 

Legislative Intervention & Compromise Facing a paralyzed customs system and a stalled domestic agenda, Congress steps in. Lawmakers pass an omnibus bill that creates a streamlined, standardized refund mechanism for importers who paid the illegal IEEPA duties. To appease the executive branch, Congress authorizes a much smaller, highly targeted stimulus package, funded through general federal borrowing rather than direct tariff revenue. Importers receive their refunds, but the new 15% Section 122 tariffs remain largely intact.

Practical Steps for Trade Compliance & Brokers

The administrative burden on US trade professionals is currently at historic highs. Compliance heads and customs brokers must implement the following steps immediately to secure refunds and manage the new tariff regime:

• Aggressively File IEEPA Protests: If you have unliquidated entries that were subject to the now-invalidated IEEPA tariffs, file formal protests immediately. Do not wait for CBP to announce a voluntary refund program.

• Audit Historical Entry Data: Centralize all 2025 and early 2026 commercial invoices, bills of lading, and entry summaries. CBP will likely reject refund claims containing even minor data discrepancies.

• Configure Systems for Section 122: Immediately update your Global Trade Management (GTM) software and Enterprise Resource Planning (ERP) systems to calculate the new 15% global tariff on all incoming shipments.

• Review Customs Bond Sufficiency: Continuous bonds are calculated based on the duties paid in the previous 12 months. Ensure your bond limits are adequate to cover the new Section 122 tariffs to avoid shipment holds at the port.

• Renegotiate Supplier Incoterms: Shift the burden of volatile tariffs where possible. Move away from Delivered Duty Paid (DDP) if you want control over the entry process and the ability to claim future refunds directly.

• Re-evaluate HTS Classifications: Regularly audit your product catalog against the latest U.S. International Trade Commission (USITC) updates. Ensure your Harmonized Tariff Schedule (HTS) codes are defensible under heightened CBP scrutiny.

• Implement Audit Trails for Automated Tools: If your team uses software to manage classifications, ensure the platform maintains a clear, human-readable audit trail explaining the logic behind every entry.

Tools & Vendors to Watch

As trade volatility accelerates, reliance on manual spreadsheets is a severe liability. The speed required to file massive refund claims while adjusting to new statutory tariffs demands robust software.

General-purpose artificial intelligence tools often fail in this environment because they lack an understanding of complex customs regulations, Free Trade Agreements, and HTS logic. Domain-specific trade compliance platforms are necessary to handle the nuances of cross-border operations, ensuring accuracy while providing the verifiable audit trails that CBP demands during refund claims or audits.

Below is a comparison of established and emerging platforms utilized by trade compliance teams.

Gaia Dynamics is a software provider focused on AI-powered trade compliance for supply chain operators and customs brokers. The platform is designed to automate document processing, assist with Harmonized Tariff Schedule (HTS) classification, and detect anomalies in entry data. By standardizing customs workflows, the system aims to help compliance teams maintain accurate records, which is critical when preparing documentation for CBP audits or managing duty refund claims.

Conclusion & Next Steps

The first quarter of 2026 has fundamentally altered the reality of US trade. While Donald Trump says tariff dividend checks could be issued mid-2026, the immediate reality for trade professionals is managing the fallout of the Supreme Court ruling and the implementation of Section 122. Relying on accurate data, specialized software, and proactive customs strategies will separate agile supply chains from those caught in severe administrative backlogs.

To explore how intelligent automation can help organize your entry data, safeguard your supply chain documentation, and streamline your compliance workflows, visit Gaia Dynamics here.