Executive Summary On August 10, 2026, CBP announced in CSMS #69486540 that the phased enforcement period for the Enhanced Air Cargo Advance Screening (ACAS) interim final rule (90 FR 52796, November 21, 2025) is extended from November 21, 2026 to May 1, 2027. The Enhanced ACAS rule, which took effect on November 21, 2025, added new mandatory, conditional, and optional data elements to the existing ACAS filing, including consignee email and phone number, shipment packing or pickup location, ship-to party, Verified Known Consignor status, and, in certain circumstances, shipper contact and customer account information, shipping cost, device identifiers, biographic data, and product listing URLs. The extension is limited in scope: CBP states that it solely affects the requirements promulgated through the Enhanced ACAS rule, is subject to the conditions in the rule’s phased-enforcement section, and that ACAS data must continue to be submitted under existing regulatory requirements. CBP says it will use the period for stakeholder outreach, technical assistance, and data quality monitoring, and expects air carriers and filers to address data quality issues, confirm that their systems can meet the technical specifications, and stay in contact with CBP. This analysis explains what the rule added, what the extension changes and does not change, and what readers commonly consider as they plan around the new date. It follows our earlier analysis of the Enhanced ACAS rule.
Enhanced ACAS Enforcement Moves to May 1, 2027: What the Extension Does and Does Not Change
(强化版ACAS全面执法推迟至2027年5月1日：延期改变了什么，没有改变什么)
1 · Background: ACAS and the 2025 Interim Final Rule
What ACAS Requires
Under 19 CFR 122.48b, the Air Cargo Advance Screening (ACAS) program requires inbound air carriers and other eligible filers to transmit specific air cargo data to CBP as early as practicable, but no later than prior to loading the cargo onto an aircraft destined for the United States. The data is analyzed through a joint CBP–TSA targeting operation that identifies high-risk cargo for further screening before it can be loaded.
What the 2025 Interim Final Rule Added
CBP published the Enhanced ACAS interim final rule (IFR) in the Federal Register on November 21, 2025 (90 FR 52796; document 2025-20606), effective that day, with comments accepted through January 20, 2026. According to the rule, CBP concluded it needed a more complete understanding of the evolving threat environment, including the parties involved in a cargo shipment transaction, the nature of their relationships, financial data related to shipments, and additional identifying information for certain online marketplaces and for shipments originating from individuals with unknown risk profiles.
CBP’s Cargo Systems Messaging Service (CSMS #66916746, November 25, 2025) summarized the data elements as follows:
| Category | Data Elements |
|---|---|
| Original mandatory elements | Shipper name and address; consignee name and address; cargo description; total quantity (smallest external packing unit); weight; air waybill number |
| New mandatory elements | Consignee email; consignee phone number; shipment packing location and/or scheduled shipment pickup location; ship-to party; Verified Known Consignor status (yes/no) |
| New conditional elements, required if the shipper is not a Verified Known Consignor | Shipper email and phone number; customer account holder, name, issuer, and number; customer account shipping frequency/volume; billing type; establishment date; IP or MAC address used when the customer account was created |
| New conditional elements, required under certain conditions | Shipping cost; IP or MAC address used to initiate the shipping transaction; biographic data; URL of the product |
| Optional | Additional optional elements, which CBP encouraged filers to provide to help expedite clearance |
Source: CBP, CSMS #66916746 and the Enhanced ACAS interim final rule, 19 CFR 122.48b(d). This is a summary; the rule and CBP’s ACAS Implementation Guide contain the full definitions and formats.
The Verified Known Consignor Pathway
The rule provides that if a shipper is designated a Verified Known Consignor by a CBP-recognized body, the filer transmits the registration number and a code identifying the designating body, and most of the conditional data otherwise required when the shipper is not a Verified Known Consignor is not required. CBP has reserved the right not to recognize a known consignor program or a particular shipper’s status. In a March 2026 version of CBP’s Enhanced ACAS FAQ, CBP stated that U.S. CTPAT was at that time the only recognized Verified Known Consignor program; readers should check CBP’s current ACAS page for any change.
⚠️ Critical Takeaway: The 2025 rule moved ACAS beyond its original set of shipment data toward information about the parties, their accounts, and in some cases the transaction itself. Which elements apply to a given shipment depends on, among other things, whether the shipper is a Verified Known Consignor.
2 · What the Extension Says
The Timeline
| Date | Event |
|---|---|
| November 21, 2025 | Enhanced ACAS IFR published and effective; 12-month phased enforcement period begins |
| January 20, 2026 | Comment period on the IFR closes |
| August 10, 2026 | CBP issues CSMS #69486540 extending the phased enforcement period |
| Original end of the phased enforcement period (now superseded) | |
| May 1, 2027 | New end of the phased enforcement period |
What CBP Said
CSMS #69486540 states that CBP is extending the phased enforcement period “to support operational readiness” and to give the trade community additional time to complete system integrations, refine compliance procedures, and resolve data quality issues. The extension is effective immediately, is subject to the conditions discussed in the IFR’s phased-enforcement section, and solely affects requirements promulgated through the Enhanced ACAS rule.
What the Extension Does and Does Not Change
| Point | Position |
|---|---|
| Is the Enhanced ACAS rule still in effect? | Yes. The rule has been effective since November 21, 2025; the extension concerns the phased enforcement period |
| Do existing ACAS requirements still apply? | Yes. CBP expects air carriers and filers to continue submitting ACAS data under existing regulatory requirements |
| Does the extension cover other programs? | CBP states it affects only requirements established through the Enhanced ACAS rule |
| What happens when the extended period ends? | The IFR stated that CBP would take prompt enforcement action against filers that do not submit the enhanced data elements once phased enforcement concludes; practitioner summaries of the rule describe the phase-in as conditioned on good-faith compliance efforts |
| Could the date change again? | CBP says it will provide further updates through future CSMS messages |
⚠️ Critical Takeaway: The extension changes the enforcement date, not the rule. Material that continues to cite November 21, 2026 as the enforcement date reflects the original schedule rather than CBP’s current position.
3 · What CBP Says It Expects During the Extended Period
CBP’s Focus
During the extended period, CBP says it will continue to focus on stakeholder outreach, technical assistance, and data quality monitoring, with the stated aim of helping air carriers, filers, and other eligible parties prepare for full enforcement.
What Air Carriers and Filers Are Expected to Do
CSMS #69486540 lists four expectations:
| # | Expectation |
|---|---|
| 1 | Continue submitting ACAS data in accordance with existing regulatory requirements |
| 2 | Promptly address any data quality issues identified by CBP |
| 3 | Confirm that internal systems can meet the technical specifications required for full enforcement |
| 4 | Maintain coordination with CBP representatives to support timely resolution of implementation concerns |
CBP Contact Channels
CBP’s message directs technical questions to the filer’s assigned Client Representative, operational inquiries to the National Targeting Center at ACAS-SUPPORT@cbp.dhs.gov, and policy-related inquiries to Cargo and Conveyance Security at OFO-MANIFESTBRANCH@cbp.dhs.gov. Readers should consult the CSMS message for the current contact details.
4 · Implementation Considerations
The following considerations are general observations that follow from the rule’s data elements and CBP’s stated expectations. They are informational rather than prescriptive, and applicability depends on each organization’s role and shipment profile.
Data Sourcing
Several of the added elements describe the consignee, the ship-to party, the packing or pickup location, and, for certain shippers, account and device information. Organizations commonly look at where each element lives in their own systems—booking records, order records, customer account systems, platform logs—and whether it can be captured consistently at the house air waybill level.
System Readiness and Testing
CBP’s expectation that filers confirm their systems can meet the technical specifications points to the ACAS Implementation Guide, which CBP updates periodically (a version dated July 27, 2026 is posted on CBP.gov). Organizations typically align message formats and validation behavior with the current guide and test with CBP before the enforcement date.
Data Quality
Because CBP states it is monitoring data quality during the extended period, organizations may find it useful to review any data quality feedback they receive, identify patterns, and trace them to the source systems or partners that supply the data.
The Verified Known Consignor Option
For shippers that qualify, the Verified Known Consignor pathway reduces the number of conditional elements that must be transmitted. Whether a given shipper holds recognized status, and which designating body issued it, is a factual question to confirm against CBP’s current guidance.
Coordination Along the Chain
ACAS data often originates with shippers, forwarders, platforms, and carriers in different systems. Organizations commonly consider how each party in the chain obtains and passes on the required data, and how discrepancies are resolved before the data reaches CBP.
⚠️ Critical Takeaway: The extended period gives time, in CBP’s words, for system integrations, procedure refinement, and data quality resolution. How an organization uses it depends on its role in the chain and its current readiness.
5 · Conclusion: A New Date, the Same Rule
CBP’s August 10, 2026 message moves the end of the Enhanced ACAS phased enforcement period from November 21, 2026 to May 1, 2027. The rule’s expanded data elements remain in effect, existing ACAS requirements continue to apply, and CBP’s stated emphasis in the interim is outreach, technical assistance, and data quality monitoring.
Key Takeaways
| Factor | Detail |
|---|---|
| Rule | Enhanced ACAS interim final rule, 90 FR 52796 (Nov. 21, 2025); 19 CFR 122.48b |
| Rule Effective Date | November 21, 2025 |
| Original End of Phased Enforcement | November 21, 2026 |
| Extension | CSMS #69486540 (Aug. 10, 2026): phased enforcement period extended to May 1, 2027 |
| Scope of Extension | Solely requirements promulgated through the Enhanced ACAS rule |
| New Mandatory Elements | Consignee email and phone; packing or pickup location; ship-to party; Verified Known Consignor yes/no |
| Conditional Elements | Shipper contact, customer account data, and device identifiers (if not a Verified Known Consignor); shipping cost, biographic data, and product URL (under certain conditions) |
| CBP Expectations During Extension | Continue ACAS submissions; address data quality issues; confirm systems meet specifications; coordinate with CBP |
| Further Updates | CBP says it will issue them through future CSMS messages |
The Bottom Line
For air carriers, forwarders, platforms, and shippers involved in U.S.-bound air cargo, the extension changes the timing of full enforcement but not the content of the rule. Organizations that would like an outside perspective on their ACAS data readiness may find it worthwhile to work with a trade compliance partner familiar with CBP’s air cargo security requirements.
The message is clear: CBP has extended the Enhanced ACAS phased enforcement period to May 1, 2027, and the rule’s data requirements remain in effect while CBP focuses on outreach, technical assistance, and data quality.
This analysis reflects CBP’s CSMS #69486540 (August 10, 2026), CBP’s CSMS #66916746 (November 25, 2025), the Enhanced Air Cargo Advance Screening interim final rule (90 FR 52796, November 21, 2025), CBP’s ACAS program materials and our earlier analysis of the Enhanced ACAS rule. CBP may issue further updates through CSMS; readers should consult CBP’s current ACAS page and implementation guide. Specific data element definitions, formats, and enforcement practices are subject to CBP guidance. Organizations should consult with customs counsel and trade compliance professionals for guidance tailored to their specific circumstances.
