CBP has moved the start of full enforcement for the enhanced Air Cargo Advance Screening data elements to 1 May 2027. The original date was 21 November 2026, and the extension was announced in CSMS # 69486540 on 10 August 2026. The filing requirement itself has been in force since 21 November 2025 and did not change.
That distinction is the whole story. What moved is the date CBP starts taking enforcement action, not the date the obligation began. Anyone who read the extension as a reprieve from filing has misread it, and the extra months are explicitly framed as time for outreach, technical assistance and data-quality monitoring rather than as a pause.
The three dates that matter
The interim final rule amending 19 CFR 122.48b took effect on 21 November 2025, with the comment period closing on 20 January 2026. CBP paired that effective date with phased enforcement, conditional on filers making good-faith efforts to comply. The phase-in was originally set to run twelve months, to 21 November 2026, and on 10 August 2026 CBP extended it to 1 May 2027.
- 21 November 2025: enhanced elements became legally required under 19 CFR 122.48b.
- 20 January 2026: comment period on the interim final rule closed.
- 21 November 2026: original end of phased enforcement, now superseded.
- 1 May 2027: new date from which CBP intends to enforce in full.
I would treat 1 May 2027 as a testing deadline rather than a build deadline. A second extension is possible, since this one arrived roughly three months before the original cut-off, but planning around a hoped-for third date is not a compliance strategy. The elements are required now, and a missing mandatory field is already a defect in the filing even while enforcement is held back.
The data elements, old and new
The pre-existing required elements are shipper name and address, consignee name and address, cargo description, total quantity based on the smallest external packing unit, total weight of cargo, and the air waybill number. The rule adds the master air waybill number as a conditional element, which the ACAS pilot did not require.
| Status | Element | Practical source |
|---|---|---|
| New mandatory | Consignee email address | Booking or e-commerce order record |
| New mandatory | Consignee phone number | Booking or order record |
| New mandatory | Shipment packing location, or scheduled pickup location | Shipper facility data, fulfilment centre |
| New mandatory | Ship to party | Order record, may differ from consignee |
| Conditional | Verified Known Consignor status | Air cargo security programme records |
| Conditional | Shipper email address and phone | Account or booking record |
| Conditional | Customer account information: name, issuer, number, frequency or volume, establishment date, billing type | Carrier or platform account system |
| Conditional | Unmasked IP or MAC address for account creation and for the shipping transaction device | Platform logs |
| Conditional | Shipping cost | Rating engine, order record |
| Conditional | Biographic data | Order or account record |
| Conditional | Link to product listing | Marketplace or webstore |
| Conditional | Master air waybill number | Consolidation record |
Read that list twice and the intent is clear. Four of the new mandatory fields describe who receives the goods and where they were packed. Most of the conditional fields describe the account and the device that created the booking, which is a direct response to low-value e-commerce parcels moving by air with thin, sometimes fabricated, party data. The same pressure produced the recent tightening on low-value shipments, and both changes push identity data upstream to whoever took the order.
Who files, and how early
The obligation sits with inbound air carriers and with other eligible ACAS filers named in the regulation, a group that includes freight forwarders, express consignment operators and, in defined circumstances, foreign indirect air carriers. The timing standard is as early as practicable and no later than loading of the cargo onto the aircraft.
That standard is looser than it sounds in one direction and tighter in another. There is no fixed hours-before-departure clock the way there is for ocean filings under the ISF 10+2 rule, so a short-haul flight and a long-haul flight face the same wording. But because the cut-off is physical loading, a late data fix is not a late filing, it is a shipment that should not have been loaded. Once a referral or a do-not-load instruction arrives, the aircraft is the constraint.
For forwarders the operational question is where the missing fields come from. When I trace them back to a system of record, consignee email is nearly always the hard one. Consignee email and phone usually exist in the order record and not in the transport record, which means the data has to be pulled from a customer's webstore or ERP into the air waybill flow. Carriers listed among the largest air cargo airlines have built that integration; small forwarders often have not.
What non-compliance costs after the phase-in
The exposure runs through the international carrier bond. Where an inbound air carrier is the bond principal and defaults on ACAS obligations, the principal and surety are jointly and severally liable for liquidated damages of 5,000 dollars for each violation, up to a maximum of 100,000 dollars per conveyance arrival. The same 5,000 dollar figure applies where another eligible party files the ACAS data and the principal defaults.
The arithmetic I check first is that per violation means per air waybill, not per flight, which is how a consolidation with dozens of house bills reaches the 100,000 dollar ceiling on a single arrival. Claims of this type can be mitigated, and the process for making that case is the same one described in our guide to CBP penalty mitigation and prior disclosure. A documented remediation plan started during the phase-in is worth considerably more in mitigation than one started after the first claim.
What to do with the extra five months
The extension moved the deadline by a little over five months. Here is where I would spend it:
- Map each new mandatory field to a system of record. Consignee email, consignee phone, packing or pickup location and ship-to party each have an owner, and it is rarely the carrier.
- Test transmissions in production volumes. Field-level rejects surface at scale, not in a sample of ten, and CBP has said it will spend the phase-in monitoring data quality.
- Decide your position on the conditional elements. IP and MAC addresses, account establishment dates and product listing links require platform cooperation and, in the EU, a privacy assessment before you can send them.
- Fix consolidation data. The master air waybill number is now a conditional element, and house-level detail is where the 5,000 dollar per violation math becomes painful.
- Write the good-faith file. Keep dated evidence of testing, vendor tickets and customer requests, since that record is the basis of any mitigation argument after 1 May 2027.
- Check who files on your behalf. If a handling agent or an express operator transmits for you, confirm in writing which elements they source and which they expect from you.
Common questions
Has the enhanced ACAS requirement been delayed? Enforcement has, not the requirement. The rule has been effective since 21 November 2025 under 19 CFR 122.48b. CBP extended phased enforcement from 21 November 2026 to 1 May 2027 in CSMS # 69486540, issued on 10 August 2026.
Does this replace the existing ACAS filing? No, it extends it. The original elements including shipper and consignee name and address, cargo description, quantity by smallest external packing unit, weight and air waybill number all remain, with four new mandatory fields and a longer conditional list added on top.
What happens if a field is genuinely unavailable? Conditional elements apply only in the circumstances the regulation defines, so an element that does not exist for a given shipment is not a violation. A mandatory element that your systems cannot produce is a different problem, and the honest answer is that the shipment should not be loaded until it can be.
Which lanes feel this first? High-volume e-commerce lanes into the US, since those are the shipments with the thinnest party data and the highest air waybill counts per arrival. The corridors in our review of the busiest air cargo trade lanes carry most of that traffic.
My read is unchanged by the new date: 1 May 2027 rewards whoever solved a data-plumbing problem rather than a compliance one. Four mandatory fields sound trivial until you trace consignee email back through a marketplace, a fulfilment centre and a forwarder's booking screen, and 5,000 dollars per air waybill is the price of not finishing that trace in time.