Executive Summary Licensed customs brokers face two sets of dates over the next six months, and they fall close together. The first set concerns maintaining the license: individual brokers must complete 20 hours of continuing education (CE) by January 31, 2027, and file the triennial status report (TSR), with a $100 fee, in the eCBP Portal during a window running from December 14, 2026 through February 28, 2027; CBP states that failing to meet these requirements results in revocation of the license by operation of law (19 CFR 111.30(d) and 111.102). Separately, the 2027 annual national permit user fee is $190.88, with its due date still to be announced in the Federal Register. The second set concerns CBP’s interim final rule on importers of record (91 FR 69977, published November 6, 2026): the rule is effective January 5, 2027, which is also the deadline for comments and for brokers to submit requests for delayed compliance with the new client-verification requirement, and all brokers are expected to be in full compliance by May 6, 2027. This calendar lists each date with its source and, in plain terms, what it involves. Dates are as published by CBP and in the Federal Register as of early November 2026 and may be updated.
Customs Broker Obligations Calendar: November 2026 Through May 2027
(报关行义务日历：2026年11月至2027年5月)
1 · The Calendar at a Glance
| Date | What Is Due or Takes Effect | Applies To | Source |
|---|---|---|---|
| Now through Jan. 31, 2027 | Complete the required 20 hours of continuing education for the current triennial period | Individual license holders subject to the CE requirement | CBP CSMS #69990316; 19 CFR 111.102 |
| Dec. 14, 2026 | TSR window opens in the eCBP Portal (CBP states the precise opening date is announced by CSMS shortly before opening) | All licensed brokers | CBP CE and TSR page |
| Date to be announced | 2027 annual national permit user fee ($190.88) due date, to be published in the Federal Register at least 60 days before it falls due | Brokers holding a national permit | CBP Customs Broker Fees page |
| Jan. 5, 2027 | Interim final rule effective; comments due; last day to request delayed compliance with the verification requirement in 19 CFR 111.29; new data fields and validation checks in entry filings take effect | All brokers; foreign IORs; U.S. IORs | 91 FR 69977; CSMS #70381183 |
| Jan. 31, 2027 | CE credits must be complete; CBP recommends filing the TSR by this date | Individual license holders | CSMS #69990316; CBP CE and TSR page |
| Feb. 28, 2027 | TSR filing window closes (with the $100 fee) | All licensed brokers | CBP CE and TSR page |
| May 6, 2027 | All brokers expected to be in full compliance with the interim final rule, including brokers with approved delayed compliance | All brokers | 91 FR 69977, Section VII |
Dates as published by CBP and in the Federal Register as of early November 2026. Readers should consult the cited sources for updates.
⚠️ Critical Takeaway: Three dates cluster in the first weeks of 2027: January 5 (rule), January 31 (CE), and the TSR window running to February 28. They arise from different requirements but can fall on the same team.
2 · Track One: Maintaining the License
Continuing Education (CE)
Under CBP’s 2023 final rule on continuing education for licensed customs brokers (codified in 19 CFR part 111), individual brokers must complete continuing broker education and certify compliance when they file the triennial status report. For the current triennial period, which closes on January 31, 2027, CBP’s CSMS #69990316 states that brokers must complete 20 hours of CE no later than January 31, 2027. The rule provides for exceptions, which are set out in 19 CFR 111.102(a). Individual brokers produce CE records only if CBP requests them under 19 CFR 111.102(d)(2).
Triennial Status Report (TSR)
| Item | Detail (per CBP) |
|---|---|
| What it is | The status report required of licensed brokers every three years under 19 CFR 111.30(d) |
| Filing window | December 14, 2026 through February 28, 2027 |
| How to file | Electronically through the eCBP Portal |
| Fee | $100 triennial fee, paid with the filing |
| CE certification | Individual brokers subject to the CE requirement report and certify compliance when they submit the TSR (19 CFR 111.102(c)) |
| License qualifiers | CBP states that a license qualifier must file the TSR on behalf of the organization, and must also complete the CE credits and file a TSR for the qualifier’s individual license |
| Recommendation | CBP recommends completing the CE and TSR requirements together by filing the TSR by January 31, 2027 |
Why There Are Two Dates
The CE deadline (January 31, 2027) and the TSR window’s close (February 28, 2027) are different requirements: the credits must be earned by January 31, and the report may be filed through the end of February. CBP’s 2023 final rule described the first triennial reporting period as closing on January 31, 2027, with the report due on February 1, 2027; CBP’s current guidance sets the filing window through February 28, 2027, and its CE and TSR page includes a note on why the dates in the regulation and on CBP.gov differ. Brokers should follow CBP’s current guidance and consult that page.
Consequence of Missing the Requirements
CBP’s message states that, under 19 CFR 111.30(d) and 111.102, failure to satisfy these requirements results in revocation of the customs broker license. CBP describes the revocation as occurring by operation of law.
Annual National Permit User Fee
| Item | Detail (per CBP) |
|---|---|
| Who pays | Brokers holding a national permit |
| Amount for calendar year 2027 | $190.88 (up from $185.38; CBP’s fee adjustment was published in the Federal Register on July 31, 2026, effective October 1, 2026) |
| Due date | Not yet announced. CBP states it will be published in the Federal Register at least 60 days before the due date, and that due dates are generally announced between November and January |
| For reference | The 2026 fee was due January 30, 2026, and the eCBP Portal accepted payments from December 2, 2025 |
| How to pay | Through the eCBP Portal |
| Consequence of non-payment | CBP states that failure to pay results in revocation of the national permit by operation of law (19 CFR 111.45(b) and 111.96(c)) |
⚠️ Critical Takeaway: The license-maintenance items are fixed by regulation and CBP guidance, with one date (the permit user fee) still to be announced. CBP describes the consequence of missing the CE and TSR requirements as revocation of the license by operation of law.
3 · Track Two: CBP’s Interim Final Rule on Importers of Record
The interim final rule, “Heightened Requirements for Foreign Importers of Record” (91 FR 69977, published November 6, 2026; docket USCBP-2026-1387), contains requirements for brokers as well as importers. For a full summary, see our analysis of the rule. The items below are those that carry dates for brokers.
January 5, 2027
| Item | What It Involves |
|---|---|
| Effective date | The rule takes effect 60 days after publication, on January 5, 2027 |
| Comments | Comments on the rule are due on or before January 5, 2027 (docket USCBP-2026-1387, Federal eRulemaking Portal) |
| Delayed compliance requests | Brokers may request delayed compliance with the new verification requirement in 19 CFR 111.29 by January 5, 2027, with an explanation of the need. Brokers currently subject to removal from CTPAT, revocation of Form 5106 filing privileges, suspension or debarment with a SAM.gov exclusion record, entry filer code suspension, or broker license revocation proceedings are ineligible. If approved, a broker must make satisfactory progress and demonstrate a good-faith effort to comply to the extent of its current ability |
| Foreign IOR entries | A foreign IOR may not enter merchandise for consumption unless it is CTPAT-validated or designates a CTPAT-validated broker (19 CFR 141.21). Delayed compliance does not postpone this restriction |
| Entry data fields | CBP’s CSMS #70381183 describes three new data fields on CBP Forms 3461 and 7501 and states that CBP may reject entries and entry summaries from January 5, 2027 in specified situations (see our analysis of that message) |
| U.S. IOR declaration | A U.S. IOR declares its qualification at entry and entry summary (19 CFR 141.22); a broker must verify a client’s qualification before making a declaration for it (19 CFR 111.29(a)(2)) |
May 6, 2027
The rule states that all customs brokers are expected to be in full compliance no later than May 6, 2027. For brokers with approved delayed compliance, that is the end of the period.
Recordkeeping Obligations Under the Rule
| Record | Retention (19 CFR 111.21 and 111.23) |
|---|---|
| Verification records (client qualification as a U.S. IOR) | Five years from the date the verification is conducted |
| Powers of attorney | Until revoked; revoked powers of attorney and letters of revocation are kept for five years after revocation or after the client ceases to be an “active client,” whichever is later |
Penalty Exposure
CBP revised paragraph (K) of Appendix B to Part 171, providing that, subject to CBP’s discretion, a broker that commits a violation of 19 U.S.C. 1592 may be subject to a penalty under section 1592 or to other enforcement action available under the law, including the remedies under 19 U.S.C. 1641.
⚠️ Critical Takeaway: The rule’s dates are a single date of effect (January 5, 2027) for most requirements, a limited delayed-compliance path for the verification requirement, and an end date of May 6, 2027.
4 · How the Two Tracks Interact
Overlapping Windows
| Window | What Is Open |
|---|---|
| Dec. 14, 2026 – Jan. 5, 2027 | TSR window open; rule not yet effective; delayed compliance requests may be submitted |
| Jan. 5 – Jan. 31, 2027 | Rule effective; CE deadline approaching; TSR window open |
| Feb. 1 – Feb. 28, 2027 | TSR window still open; rule in effect; delayed compliance (if approved) running |
| Mar. 1 – May 6, 2027 | Rule in effect; delayed compliance (if approved) runs to May 6 |
Connections Between the Tracks
- Delayed compliance eligibility depends on license and program standing. The rule makes brokers subject to broker license revocation proceedings, entry filer code suspension, CTPAT removal, and certain other actions ineligible for delayed compliance.
- CTPAT status matters on both the rule and the client side. Under the rule, a CTPAT-validated broker can make entry for or act as IOR for a non-validated foreign IOR; a non-validated broker cannot.
- The same personnel often handle both. License qualifiers file the TSR for the organization and may also be responsible for rule implementation.
5 · Implementation Considerations
The following considerations are informational and not prescriptive; applicability depends on each broker’s license structure, client mix, and CTPAT status.
| Area | Commonly Raised Consideration |
|---|---|
| CE completion | How many individual license holders in the organization still need credits, and whether any exceptions under 19 CFR 111.102(a) apply |
| TSR filing | Who files for each license and for the organization; whether the TSR will be filed with the CE certification by January 31, as CBP recommends |
| Permit user fee | Who monitors the Federal Register and CSMS for the 2027 due date, since it has not yet been announced |
| Rule effective date | Systems and procedures for the three new entry data fields and the validation checks from January 5, 2027 |
| Client verification | Procedures for requesting and reviewing client records under 19 CFR 111.29(a)(2), and for five-year retention |
| Delayed compliance | Whether a request is warranted, whether the broker is eligible, and the January 5 deadline for requests |
| CTPAT status | Whether the broker is CTPAT-validated, and the implications for foreign IOR clients |
| Powers of attorney | Whether powers of attorney are in place for all customs business, including entries where the broker acts as IOR |
⚠️ Critical Takeaway: The calendar items are discrete, but the people and systems involved overlap. A single list of owners and dates is one way organizations keep them in view.
6 · Conclusion: A Cluster of Dates
Between now and May 2027, licensed customs brokers have a license-maintenance track (CE by January 31, the TSR window through February 28, and the 2027 permit user fee) and a rule-implementation track (January 5 and May 6). The two tracks are separate in source and consequence, but the dates sit close together in the first quarter of 2027.
Key Takeaways
| Factor | Detail |
|---|---|
| CE Deadline | 20 hours by January 31, 2027 (CSMS #69990316) |
| TSR Window | Dec. 14, 2026 – Feb. 28, 2027; $100 fee; eCBP Portal; CBP recommends filing by Jan. 31 |
| Consequence (CE/TSR) | Revocation of the license by operation of law (19 CFR 111.30(d), 111.102) |
| 2027 Permit User Fee | $190.88; due date to be announced in the Federal Register |
| IFR Effective Date | Jan. 5, 2027 (91 FR 69977) |
| Delayed Compliance Requests | By Jan. 5, 2027; verification requirement (19 CFR 111.29) only; certain brokers ineligible |
| Full Broker Compliance | May 6, 2027 |
| Recordkeeping | Verification records: five years from verification; powers of attorney: until revoked, then five years |
| Penalty Guidelines | Revised paragraph (K), Appendix B to Part 171: section 1592 or other action, including section 1641 |
The Bottom Line
The calendar shows what CBP has published and when, but each broker’s position depends on its own license structure, clients, and CTPAT status. Organizations that would like an outside perspective on their broker compliance calendar may find it worthwhile to work with a trade compliance partner familiar with CBP’s licensing and IOR requirements.
The message is clear: for licensed customs brokers, the first months of 2027 combine license-maintenance deadlines with the effective date of CBP’s importer-of-record rule, and the published dates are January 5, January 31, February 28, and May 6.
This analysis reflects CBP’s CSMS #69990316 on broker continuing education, CBP’s pages on the Triennial Status Report and Continuing Education requirements and Customs Broker Fees, the Federal Register notice of CBP’s final rule on continuing education for licensed customs brokers (June 23, 2023), CBP’s interim final rule Heightened Requirements for Foreign Importers of Record (91 FR 69977, November 6, 2026), CBP’s CSMS #70381183, and 19 CFR 111.30, 111.45, 111.96, and 111.102. Dates and fees are as published by CBP as of early November 2026 and may be updated; readers should consult CBP’s current guidance. Organizations should consult with customs counsel and trade compliance professionals for guidance tailored to their specific circumstances.
