2026 Tariff Playbook for Controllers and FP&A

• • 5 min read

For finance leaders, the trade uncertainty that dragged on through 2025 is no longer temporary. Going into 2026, tariffs are now a normal part of doing business. At the same time, governments are enforcing trade rules more aggressively, and global political tensions continue to rise. This means finance teams cannot just react to higher costs after they happen. They need a clear, coordinated strategy. Controllers and FP&A teams each play different roles, but their work is closely connected. This playbook explains how both groups should approach tariffs and trade risk in 2026. “Tariffs are no longer a temporary problem. They are now built into the global economy, and 2026 plans must reflect that.”

2026 Tariff Playbook for Controllers and FP&A

1. Tariff Compliance Is Now a High-Stakes Game of Accuracy

Governments are cracking down on trade violations more than ever. Customs fraud is no longer treated mainly as a paperwork issue. It is now a target for criminal enforcement. A new DOJ–DHS Trade Fraud Task Force is actively focusing on customs fraud, especially schemes that hide the true country of origin for goods, often involving China.

This raises both financial risk and reputational risk to a new level.

For Controllers: Strengthen Internal Controls

Controllers are responsible for making sure customs data is accurate and reliable. With increased enforcement, strong internal controls are the first line of defense. Key steps include:

For FP&A: Model the Risk of Non-Compliance

FP&A teams need to look beyond normal tariff cost forecasting. The bigger risk in 2026 is the financial impact of getting compliance wrong.

This means modeling worst-case outcomes, including large penalties under laws like the False Claims Act. One real example is the Ceratizit case, where a company paid $54.4 million for falsely stating the country of origin of Chinese goods. The whistleblower alone received nearly $10 million.

FP&A should compare the cost of investing in better compliance systems, technology, and training against the risk of massive fines, legal costs, and reputational damage.

2. The Biggest Tariff Event of 2026 Could Be a Refund

A major unknown in U.S. trade policy depends on the Supreme Court’s decision in Trump v. V.O.S. Selections, Inc. The case questions whether tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were legal.

The ruling could go several ways. The Court could uphold the tariffs, change them, or strike them down entirely. If the tariffs are invalidated, companies may be able to claim refunds for duties they already paid.

For Controllers: Get the Paperwork Ready

If refunds become available, companies will need to move fast. Controllers should make sure that all customs entries, proof of duty payments, and related documents for IEEPA-related tariffs are fully digitized and easy to audit.

Refund claims often have strict deadlines, so having clean, organized data could make the difference between recovering cash or missing the opportunity.

For FP&A: Plan for Uncertainty

FP&A teams should prepare leadership for multiple outcomes by building flexible financial models:

3. Your Newest “Tariff” Is a Carbon Tax in Disguise

Starting January 1, 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) moves into full financial enforcement. CBAM acts like a tariff by charging importers for the carbon emissions tied to certain products, including steel, aluminum, cement, iron, and fertilizers.

The goal is to match the carbon costs paid by EU producers under the EU Emissions Trading System. The challenge is that companies must now collect detailed emissions data from suppliers outside the EU.

For Controllers: Own Emissions Reporting

Even though EU importers are legally responsible for CBAM payments, the data burden spreads across the entire supply chain.

Controllers must build systems to collect, verify, and report emissions data from non-EU suppliers. This creates a new type of financial reporting challenge that requires strong data controls and governance.

For FP&A: Forecast Carbon Costs

FP&A teams should treat CBAM as a new variable in landed cost calculations. This means forecasting future carbon prices and linking them to supplier emissions data.

FP&A should also compare sourcing strategies. A higher-priced supplier with lower emissions may be cheaper in total once CBAM costs are included. Teams should also model the risk that CBAM expands to more products, which could raise costs beyond raw materials.

4. Your Supply Chain “Fix” Is Creating New Problems

To reduce risk, many companies have diversified suppliers or moved production closer to home. While these strategies make sense, they also create new compliance and financial risks.

The 2026 review of the USMCA agreement is expected to increase scrutiny of rules of origin and transshipment, especially goods routed through Mexico or Canada from China.

For Controllers: Do Deeper Due Diligence

Every new supplier or route introduces risk. Controllers should screen for issues beyond basic financial checks, including:

For FP&A: Calculate the Full Cost of Diversification

FP&A models should capture more than production and shipping costs. The true cost of diversification includes:

Including these factors helps leadership make fair comparisons between sourcing options.

Conclusion: From Reactive Defense to Strategic Advantage

Tariffs and trade rules are no longer short-term disruptions. They are a permanent part of the global economy.

Companies that succeed in this environment will be those where Controllers and FP&A teams work closely together. Controllers bring precision, controls, and compliance discipline. FP&A brings forward-looking analysis and strategic insight.

Together, they can turn trade strategy from a reactive cost problem into a long-term competitive advantage.

Is your finance team ready for the trade reality of 2026, or is it still planning as if it were 2016?

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