How to audit a customs broker invoice line by line against the Form 7501 and the CBP statement

What is a broker invoice, and what is it not?

A customs broker invoice is a bill for two different things. Part of it is money the broker paid, or will pay, to CBP for you: duty, the merchandise processing fee (MPF), the harbor maintenance fee (HMF), any AD/CVD deposit and other charges in block 43 of the entry summary. The rest is the broker's own price for filing the entry and for related services. Only the first part is customs duty, and only the entry summary and CBP's statement prove what it should have been.

The invoice is not proof that CBP was paid. 19 CFR 141.1(b)(1) makes duty "a personal debt due from the importer to the United States" and says payment to a broker "does not relieve the importer of liability if the duties are not paid by the broker". 19 CFR 111.29(b) obliges every broker to give clients that warning in writing. So the audit has two ties for each pass-through line: to the 7501, for what should have been paid, and to the CBP statement, for what was paid.

This page is about the invoice itself. Booking duty from the entry rather than from the invoice is covered in duty accrual vs what you actually paid, and the wider three-way match of invoice, entry export and ERP in reconciling broker entry exports with invoices and your ERP.

Which documents do you need for each entry?

1. The broker invoice, with the entry number on it. Ask for one invoice per entry, or an entry-level breakdown on a consolidated invoice.
2. The entry summary (Form 7501) or the broker's entry export with the same fields: entry type and ABI indicator in block 2, columns 37 and 38 per line, and blocks 41 to 44.
3. The CBP statement that paid the entry. Block 2 of the 7501 carries the ABI status: "ABI/A" for an ACH statement, "ABI/P" for a periodic monthly statement, "ABI/S" for a statement paid by check or cash, "ABI/N" for a summary not paid on a statement (Form 7501 instructions, revision 02/26). The statement shows the statement number, the payer and the amount per entry.
4. Liquidation records: the liquidation date and any bill or refund, for entries old enough to have liquidated.
5. Your contract or rate sheet with the broker, for the service charges.

Brokers must keep their records of account for at least five years after the date of entry (19 CFR 111.23(b)), so the broker can supply the detail behind any invoice in that period.

How do the duty and fee lines tie to the 7501?

The Form 7501 instructions define the totals:

The MPF is 0.3464 percent of the entered value of a formal entry (19 CFR 24.23(b)(1)), within a minimum and maximum that change each fiscal year: $34.58 and $670.86 for entries dated from October 1, 2026 (CBP Dec. 26-14, 91 FR 48398), which left the percentage unchanged. The HMF is 0.125 percent of the value of cargo unloaded from a vessel at a listed port (19 CFR 24.24, as in force on November 10, 2026). Recomputing them is covered in MPF, HMF and the other Form 7501 fees. For the invoice, the test is simpler: each fee on the invoice should equal the same code in block 43.

Worked invoice: one entry, three findings

An illustrative invoice for one formal entry of $120,000 entered value, entered November 2, 2026, vessel cargo at a listed port, paid on the broker's ACH daily statement. The entry summary shows block 41 duty $31,800.00, block 43 MPF $415.68 and HMF $150.00, and block 44 $32,365.68.

The $3,000 line is the finding to look for first on stacked entries. The 7501 reports each Chapter 99 duty against its own heading and adds it into block 41, so an invoice that bills block 41 as "duty" and then lists a Section 301, Section 232 or AD/CVD amount separately must show that the separate line is a breakdown, not an addition. AD/CVD is the exception: it sits in block 43, not 41, so an AD/CVD line on the invoice should match codes 012 and 013. The disbursement fee is also worth a look. No CBP rule sets it; it is whatever the rate sheet says. Where the rate sheet prices it as a percentage of the duty the broker advanced, it moves with every stacked rate, and a duty line billed twice inflates it too.

How do you tie the invoice to the CBP statement?

The 7501 says what should have been paid; the statement shows who paid it and when.

• Daily statements. Under 19 CFR 24.25(c)(3), the ABI filer using statement processing "is responsible for ensuring that payment is made within 10 days of the entry". The final statement, generally available the day after ACH payment, is evidence that payment occurred (24.25(c)(4)(iii)).
• Periodic monthly statements. CBP's PMS test notice (90 FR 48314, October 16, 2025) has CBP send ACH debit authorizations to the bank on the 15th working day of the month following the month the goods were entered or released, unless an earlier date is chosen. A June entry on a PMS is paid in July, so an invoice dated in June that bills duty may be billing money not yet paid to CBP.
• Who paid. If you pay CBP directly from your own account, 24.25(b)(2) has CBP assign a payer unit number to your bank account, which you give the broker to use on your statements. Where your payer unit number paid the statement, the broker should not also bill you the duty.
• Timing of the broker's payment. 19 CFR 111.29(a) requires a broker to pay the Government on or before the due date and, for client money received after the due date, within 5 working days of receipt. From January 5, 2027, this text becomes 111.29(a)(1) under the interim final rule at 91 FR 69977 (published November 6, 2026), which adds a separate duty to verify that a client qualifies as a U.S. importer of record, with full compliance expected by May 6, 2027; the payment wording is unchanged.

Match each invoice to the statement entry by entry: statement number, statement date, payer and amount. An entry billed by the broker but paid by your payer unit number is a duplicate payment. An entry billed and never shown as paid is a liability that is still yours under 141.1(b)(1).

What happens to the invoice after a correction or liquidation?

Duty on an entry changes after filing, and the invoice usually does not.

1. Post-summary corrections. A PSC is "essentially a new entry summary" and is not processed until fully paid (CBP's PSC page). An increase means a further payment, and the broker may bill it separately; a decrease means a refund at liquidation. Check that the invoice series follows the corrected block 44, not the original.
2. Liquidation bills. Under 19 U.S.C. 1505(b), a bill for increased duty is due 30 days after issue, with interest under 1505(c). PMS participants must pay supplemental duty bills electronically by ACH from December 15, 2025 (90 FR 48314).
3. Refunds. 19 CFR 24.36(b) certifies refunds to the importer of record, but 24.36(a) lets a CBP Form 4811 direct them to someone else, and a refund is issued to the attorney under a power of attorney where that is requested. A refund that went to the broker should come back to you. 19 CFR 111.29(a) requires the broker to give a written statement accounting for funds "received for the client from the Government" within 60 calendar days of receipt, unless it pays them over.

The refunds deserve their own list, because they arrive months or years after the invoice and are easy to lose. Book them as accounting for customs duty refunds describes.

What does finance do with the result?

Split every broker invoice into three buckets before it is posted:

• Customs charges: the pass-through lines that tie to block 44. They belong with the entry, as duty and fees in landed cost, and should be booked from the entry, not the invoice.
• Service charges: entry fees, per-line fees, bond, filing and disbursement fees. They are the broker's price and are tested against the rate sheet.
• Differences: anything billed as a customs charge that does not tie to block 44 or to the statement. These are claims against the broker, not against CBP, and the route is a credit note, not a protest. 19 CFR 111.29(a) backs the claim: a broker must give a written accounting within 60 calendar days for money received from a client in excess of the government charges properly payable, or received where no payment to the Government was made, unless it pays the money back.

The distinction matters because the remedies differ. An error in the entry itself, a wrong rate or value, goes back to CBP through a correction, protest or prior disclosure with your broker. An error in the invoice, a duplicate line or a fee that does not match the entry, is settled with the broker. The windows for the first kind are in how long you have to fix a past entry.

How do you audit a whole period of broker invoices?

1. Collect every broker invoice, the entry export for the same entries and the CBP statements for the period.
2. Split each invoice into customs charges, service charges and other lines.
3. Tie customs charges per entry to block 41, the block 43 codes and block 44. List every difference by entry.
4. Tie each entry to its statement: payer, statement date and amount. Flag entries paid by your own payer unit number but billed by the broker, and entries billed but not paid.
5. Test service charges against the rate sheet, with attention to percentage-of-duty fees on stacked entries.
6. Track the after-life: PSCs, liquidation bills and refunds per entry, and whether each refund reached you within the 60 days 111.29(a) allows for the broker's accounting.
7. Send the list to the broker with entry numbers, overbillings and underbillings both.

Rate and value errors in the entry itself are a separate audit: the post-entry audit guide covers them line by line, and the audit page explains how to run one on your history. TariffSense reads entry summaries and broker exports and checks each entry's duty and fees against the measures in force on its entry date, so the block 44 each invoice should match is recomputed, not copied. Questions about a broker's obligations under 19 CFR part 111 are for your broker or customs counsel.