Executive Summary
U.S. Customs and Border Protection has announced enhanced enforcement procedures to verify the accuracy of importer of record (IOR) information submitted on CBP Form 5106, the Create/Update Importer Identity Form. Beginning September 18, 2026, CBP will immediately void any IOR number tied to inaccurate or incomplete Form 5106 data—rendering the number invalid for any purpose, including making entry. This is not limited to new applicants: CBP has stated it is comprehensively reviewing the Form 5106 data behind every IOR number currently on file, regardless of when the account was opened. The measure is one of the first concrete implementation steps under Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. This analysis examines what CBP is verifying, why several long-accepted industry practices are now compliance risks, and what importers and customs brokers should do before the enforcement date.

CBP Will Begin Voiding Importer of Record Numbers on September 18

(CBP将于9月18日起注销信息不准确的进口商记录编号)

1 · What’s Changing: From Registration Formality to Active Verification

The Announcement

CBP has announced plans to verify the accuracy of the information provided by new and existing importers of record on CBP Form 5106. The notice, published in the Federal Register on August 19, 2026, states that CBP is comprehensively reviewing the CBP Form 5106 information on file for all importers of record—not just applications submitted going forward.

Why This Matters: for most companies, Form 5106 has historically functioned as a one-time registration formality completed years ago and rarely revisited. CBP’s announcement changes that calculus entirely. An IOR number that has worked without issue for a decade can now be voided if the underlying Form 5106 data no longer holds up to scrutiny—whether because the business relocated, restructured, changed banking relationships, or was originally registered with information that was inaccurate or incomplete from the start.

What Form 5106 Actually Requires

To become an IOR and make entry in the United States, an individual or entity—or a licensed customs broker acting on their behalf—must submit a Form 5106 containing several required data elements: importer name, Internal Revenue Service employer identification number, Social Security number or CBP-assigned number, mailing address, physical location address (if different from the mailing address), phone number, and email address. The form also includes several optional data elements, such as information regarding the company’s business structure, beneficial ownership, and company officers.

The September 18 Deadline

Beginning September 18, 2026, if CBP determines that inaccurate or incomplete information has been provided on Form 5106, the associated IOR number will be voided, rendering it invalid for any purpose, including entering imports into the United States. CBP has been explicit that this consequence is immediate—there is no grace period once a discrepancy is identified.

2 · The Legal Basis: Executive Order 14411

This enforcement action traces directly to Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. Section 2(e) of the order directs the Secretary of Homeland Security to confirm that active importers of record are compliant with all applicable regulations and disclosure requirements.

CBP’s Form 5106 review is the agency’s first concrete implementation step under that directive—and, by multiple accounts, a more aggressive one than many in the trade community expected. It also connects directly to the broader enforcement buildout we have tracked in earlier analyses: the same executive order that produced this Form 5106 review also requires foreign importers of record to be CTPAT-validated or represented by a CTPAT-validated broker, and CBP has stated that broader revisions to importer eligibility regulations, policies, and guidance remain under development. Form 5106 accuracy should be understood as one piece of a larger, still-unfolding compliance framework rather than an isolated, one-time requirement.

3 · What CBP Is Actually Scrutinizing

Several data points that many companies treat as settled, low-risk formalities are now specific points of exposure:

The Physical Address Test

CBP requires a physical location address, distinct from a mailing address, when the two differ. A useful test that compliance advisors have suggested: if a CBP officer visited the physical address on file, would they find the business actually operating there? A registered agent’s office, a virtual mailbox, or an address the company no longer occupies would each fail this test.

Data That Belongs Directly to the IOR

CBP requires that each data element belongs directly to the IOR—not to a freight forwarder, a customs broker, a parent company, or another third party filing on the importer’s behalf. Businesses that were originally registered using a service provider’s address or contact information, for administrative convenience, should treat this as a discrepancy CBP is now positioned to catch.

Valid Power of Attorney for Broker-Filed Forms

Where a customs broker submits Form 5106 information on an importer’s behalf, the broker must possess a valid Power of Attorney executed directly with the importer. A POA obtained indirectly—for example, through a freight forwarder rather than the importer itself—does not satisfy this requirement. Brokers should audit their POA files for exactly this kind of indirect arrangement before September 18.

Up-to-Date Business Details

Beyond the address, CBP expects the full record—including business structure, and where provided, beneficial ownership and company officer information—to remain current. A business that has changed its legal structure, ownership, or officers since its Form 5106 was originally filed, without updating CBP, carries meaningful exposure under the new review.

4 · The Consequences of a Voided IOR Number

Immediate Operational Impact

A voided IOR number is invalid for any purpose, including making entry. Because the void takes effect immediately upon CBP’s determination, cargo already in transit can arrive with nowhere to clear—stopping at the port with no advance warning to the importer.

The Reestablishment Process

CBP will send written notice to the email address on file explaining the basis for the void and providing instructions for requesting reestablishment. To request reestablishment, the standard process involves contacting CBP at IORProgram@cbp.dhs.gov, with “Enforcing IOR Accuracy” in the subject line, and providing documentation sufficient to prove identity and ownership. Historically, this reestablishment process has taken approximately five business days—a meaningful supply chain disruption for any importer caught off guard.

Legal and Financial Exposure Beyond the Voided Number

CBP has been clear that voiding the IOR number is not necessarily the only consequence. Parties certifying Form 5106 may face fines, imprisonment, or other legal consequences for making an intentional false statement or committing deception or fraud on the form—including potential exposure under 18 U.S.C. § 1001, the general federal false statement statute.

Because IOR data functions as a key identifier for liability related to the payment of duties, inaccurate or misleading information on Form 5106 is considered material to an obligation to pay money to CBP. This can expose the IOR or associated individuals to liability under the False Claims Act or other laws—the same enforcement tool that features prominently in DOJ’s broader trade fraud enforcement priorities, as we examined in our earlier analysis of the joint DOJ-DHS Resource Guide to Trade Fraud Enforcement.

Broker-Specific Exposure

Customs brokers who submit inaccurate or invalid information on a Form 5106 may also be subject to broker penalties or other consequences under 19 U.S.C. § 1641. CBP reminds brokers that they must exercise due diligence and should not transmit information they know, or should know, is false, misleading, or unverified—reinforcing the heightened due diligence standard already taking shape for brokers under Executive Order 14411’s broader provisions.

5 · What Importers Should Do Now

1. Treat This as a Comprehensive Review, Not a New-Applicant Rule

CBP has stated it is reviewing the data behind every IOR number on file, regardless of whether it was opened last month or decades ago. Importers should not assume that a long-standing, previously trouble-free IOR number is exempt from this review.

2. Pressure-Test the Physical Address

Confirm that the physical location address on file is the business’s actual, current operating location—not a registered agent, a virtual office, or an address the company has since vacated.

3. Confirm Data Belongs Directly to the IOR

Review whether any required data elements—address, phone number, email—were originally filed using a third party’s information rather than the importer’s own. Where they were, file a correction before September 18.

4. Audit Power of Attorney Arrangements

Importers working with a customs broker should confirm the broker’s POA was executed directly between the importer and the broker, not obtained indirectly through a freight forwarder or other intermediary.

5. Update Business Structure and Ownership Information

Where business structure, ownership, or company officer information has changed since the original Form 5106 filing, submit an updated form promptly rather than waiting for CBP to identify the discrepancy.

6. Build a Contingency Plan

Given that reestablishment has historically taken about five business days, importers with time-sensitive shipments should have a documented contingency plan—including advance notice to logistics partners—in case an IOR number is voided unexpectedly.

7. Customs Brokers: Review Every File

Brokers filing Form 5106 on behalf of clients should audit their full book of business for POA validity and data accuracy now, given their own direct exposure to broker penalties under 19 U.S.C. § 1641 for submitting inaccurate information.

6 · Conclusion: A Deadline That Rewards Early Action

The Bottom Line

CBP’s Form 5106 review represents a meaningful shift from passive registration to active, ongoing verification—and it applies retroactively to every IOR number already on file, not just new applications. Given that a voided number halts entry immediately and reestablishment can take roughly a week, the cost of discovering a discrepancy after September 18 is considerably higher than the cost of finding and correcting it beforehand.

The Strategic Takeaway

Organizations that treat Form 5106 accuracy as a routine annual compliance check going forward—rather than a one-time filing from years past—will be far better positioned as CBP continues rolling out the broader importer eligibility framework contemplated under Executive Order 14411.

Organizations navigating Form 5106 accuracy, broker power-of-attorney arrangements, or the broader Executive Order 14411 importer framework may find it worthwhile to have a trade compliance partner review their records with fresh eyes.

This analysis reflects CBP’s general notice, “Accuracy of Importer of Record Data Submitted to CBP,” published in the Federal Register on August 19, 2026 (91 FR 53627, Doc. 2026-16911), implementing Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026 (91 FR 35125). Enhanced enforcement, including immediate voiding of IOR numbers tied to inaccurate Form 5106 information, commences September 18, 2026. Organizations should consult with customs brokers and trade compliance professionals for guidance tailored to their specific circumstances.