How do you tie a CBP periodic monthly statement to your entries?

What is a periodic monthly statement?

A periodic monthly statement (PMS) is CBP's monthly bill for estimated duties, taxes and fees on the entries an importer or its broker scheduled for monthly payment. It runs as a National Customs Automation Program test that CBP announced at 69 FR 5362 on February 4, 2004 and has modified fourteen times since, most recently at 90 FR 48314 on October 16, 2025. The statute behind it is 19 U.S.C. 1505(a), which directs regulations letting a participating importer deposit estimated duties and fees "no later than the 15 working days following the month in which the merchandise is entered or released".

Participation needs ABI filing, ACH debit or ACH credit payment, a bond that covers the periodic payments and an account in good standing with CBP (90 FR 48314). Payment can be made under the importer's own payer unit number or under the broker's: 19 CFR 24.25(b)(2) has CBP assign a unique payer's unit number to each participant, and clients paying through a broker get their own numbers directly from CBP.

The statement pays for entries. It does not say whether the duty on each entry was right; that is the entry summary's job. A statement audit therefore asks three things: is every entry on the right statement, does each amount match the entry, and who paid.

How does an entry travel onto a statement?

The PMS notice describes four statements, two daily and two monthly. Each is a checkpoint you can tie to.

Two timing rules decide which month an entry belongs to. First, the month is the one "in which the merchandise is either entered or released, whichever comes first" (90 FR 48314). Second, for incremental releases under one entry, the release of the first portion "will identify the month that the entry is filed and establishes the obligation to pay". A large shipment released across a month end is paid with the first month's statement.

Three kinds of entry cannot go on PMS at all: reconciliation entries, USMCA duty deferral entries and entries requiring the payment of excise taxes. Those are paid by other means, so a month's statement total should never equal the total of every entry the importer filed that month.

When is each month's statement paid?

For ACH debit, CBP sends the debit authorizations to the bank "on the 15th working day of the month following the month in which the merchandise is either entered or released", and the money must be in the account by then. For ACH credit, CBP must receive the payment by the 15th day of the following month, or the preceding business day if the 15th is a weekend or holiday.

Counting working days is where finance calendars drift. 19 CFR 101.6(a) lists the national holidays on which CBP offices close, including "the eleventh day of November" and "the fourth Thursday of November". For goods entered in October 2026, the 15th weekday of November 2026, skipping Veterans Day on Wednesday, November 11, is Monday, November 23. A cash forecast that counts fifteen business days without the holiday lands on November 20 and is a day early. An ACH credit payer has a different date: November 15, 2026 is a Sunday, so its payment for October entries had to reach CBP by Friday, November 13. The debit date printed on the preliminary statement is the one to trust.

How do you tie a statement to entries and the broker invoice?

Work from the statement outward, entry by entry.

1. List the month's entries from your entry export: entry number, entry date, release date, ABI status in block 2, and block 44 of each 7501.
2. Assign each to a statement month by the earlier of entry date and release date, and leave out entries not on ABI/P and the excluded entry types.
3. Match to the preliminary monthly statement. Every entry assigned to the month should be on it, once. Missing entries, entries on a later month's statement and entries listed twice are findings.
4. Match the amounts. Each statement amount should equal the entry's duties, taxes and fees as filed; on the 7501 that total is block 44, which the Form 7501 instructions define as the sum of blocks 41 (duty), 42 (tax) and 43 (other fees and AD/CVD), without deferred tax or bonded AD/CVD.
5. Check the payer. If the statement was paid under your own payer unit number, the broker paid nothing to CBP for those entries and its invoice should carry no duty disbursement for them. If it was paid under the broker's number, the invoice should pass through exactly the statement amount.
6. Tie the final statement to your bank debit and to the general ledger, and keep both with the entry records.

The broker invoice side, splitting pass-through money from service charges and chasing refunds that went to the broker, is covered in how to audit a customs broker invoice. The accrual side, where finance booked a standard rate weeks before the statement, is in duty accrual vs what you actually paid. This page is the link between them.

What does a tie-out look like on one month?

An illustrative importer pays on PMS under its own payer unit number. Its October 2026 entry export shows three ABI/P entries. The entry summary for C was filed on November 6, within 10 working days of entry, but the filing date does not move an entry to a later month.

The October preliminary statement shows $16,585.86 (A plus B) for debit on November 23, 2026. The tie finds two things.

• Entry B was paid twice. CBP debited the importer's account for it on the statement, and the broker invoiced it as a disbursement. Under 19 CFR 141.1(b)(1), duty is the importer's personal debt and payment to a broker does not discharge it unless the broker pays CBP; here the broker did not need to pay at all. The $4,105.66 is a credit-note claim against the broker, not a CBP matter.
• Entry C sits a month late. Entered and released October 30, it belongs to the October statement, debited November 23, 2026; on the November statement it would be paid in December. The PMS notice warns that an entry removed from a periodic daily statement after the 10-working-day period "may be the subject of a claim for liquidated damages for late payment". Ask the broker how the entry was scheduled and correct the process before CBP raises it.

The statement total of $16,585.86 against an October export total of $23,908.36 also explains itself only once entry C's month is fixed. A statement that ties in total can still hide both findings; the tie has to be per entry.

What happens after the statement is paid?

The statement pays estimated amounts. Each entry still liquidates, and the money can move again.

• Underpayments. A liquidation bill is due 30 days after it is issued (19 U.S.C. 1505(b)). Since December 15, 2025, PMS participants must pay supplemental duty bills by ACH debit or ACH credit (90 FR 48314). Interest under 19 U.S.C. 1505(c) runs from the date the deposit was required, which for a PMS entry is the statement due date.
• Overpayments. Refunds are paid within 30 days of liquidation with interest (1505(b) and (c)) to the importer of record or the party a CBP Form 4811 names, not back through the statement.
• Missed payments. A participant that fails to deposit on time can be suspended from the test, immediately in cases of non-payment or late payment (90 FR 48314).

How do you keep statements and entries tied every month?

Make the tie part of the close, not a year-end exercise.

1. Pull the preliminary monthly statement when CBP issues it, by the 11th calendar day, and run steps 1 to 5 before the debit date.
2. Clear findings with the broker before the debit: a missing entry, a wrong month or a double bill is easier to fix before money moves.
3. Keep the final statement, the bank debit and the per-entry tie with the entry records.
4. Feed the entry amounts, not the statement total, into the duty accrual true-up.

The amounts on the statement are only as right as the entry summaries behind them. The post-entry audit guide covers checking those lines, and the MPF and HMF page the fees in block 43. TariffSense reads entry summaries and broker exports, groups ABI/P entries by statement month and flags entries on the wrong month, block 44 amounts that differ from the statement, and duty billed by the broker on entries the importer's own payer unit number paid. The audit page explains how to run it on your history. Questions about your PMS participation or bond are for your broker or CBP.