Executive Summary
CBP’s enforcement start date, September 18, 2026, has passed. From that date, CBP says it will immediately void an importer of record number if it finds the Form 5106 information on file inaccurate or incomplete.
The physical address must be the IOR’s actual location. The email address and phone number must be valid and belong to the IOR, not a broker or another party.
A voided number is invalid for any purpose, including entering merchandise. CBP says it will send written notice after voiding, provides for no advance warning, and does not say how long a reestablishment request takes.
The June 3, 2026, executive order also directs further changes to IOR eligibility, good standing, the registry and vetting within 180 days. November 30, 2026, is the calculated 180-day deadline from the order’s signing date.
CBP’s Federal Register notice on Form 5106 accuracy, published August 19, 2026, set September 18, 2026, as the start date for enhanced enforcement. From that date, CBP will void an importer of record number if it finds information on file inaccurate or incomplete. The notice applies to new and existing IORs, including submissions customs brokers make on an IOR’s behalf. It describes a void followed by written notice, with no advance warning.
Which Form 5106 Data Is CBP Checking?
CBP says it is conducting a comprehensive accuracy review of Form 5106 information on file. Required data includes the importer name; an IRS 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 asks for optional information, including details about the company, business structure, beneficial ownership and company officers.
CBP stresses that the information must be accurate and complete. The physical address, email address, phone number, EIN and any SSN provided must belong directly to the IOR. Form 5106 may be filed through the Automated Broker Interface or emailed to the appropriate Center of Excellence and Expertise. That is the IOR’s assigned Center or, if no Center has been assigned, the one that most closely aligns with the tariff classification of the IOR’s highest valued commodity.
What Address Must an IOR Use on Form 5106?
The physical address must identify the actual location of the business or individual. CBP says it cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center or another person’s or entity’s address. The notice also says a principal’s home address can be the address associated with the business.
The IOR must have a valid email address and phone number, and both must belong to the IOR. A broker or other third party cannot provide its own contact information, or another person’s or entity’s details, instead. Since CBP is reviewing information already on file, IORs should check existing records as well as new submissions.
What Happens When CBP Voids an IOR Number?
If CBP finds Form 5106 information inaccurate or incomplete, it says it will immediately void the associated IOR number. The number will be invalid for any purpose, including entering imported merchandise into the United States. CBP may also take other enforcement action.
CBP will send written notice to the email address the IOR most recently submitted. The notice will explain the basis for voiding and how to request reestablishment, including the information the IOR must submit to corroborate its identity. If applicable, CBP will copy the broker that last filed an entry for the IOR.
Send reestablishment requests by email to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.” The IOR, or a customs broker with a valid power of attorney, may also email that address with questions about a voided number. For a broker, a valid power of attorney is one executed directly with the IOR, not through a freight forwarder or other third party.
The notice says the party certifying Form 5106 may face fines or imprisonment under 18 U.S.C. 1001, or other legal consequences, for an intentional false statement or deception or fraud on the form. It also states that inaccurate or misleading information is material to an obligation to pay money to CBP and could expose the IOR or associated individuals to False Claims Act liability. Brokers that submit inaccurate or invalid information may face broker penalties or other consequences.
What Does E.O. 14411 Change for Importers of Record?
The executive order on strengthening customs enforcement, signed June 3, 2026, directs the DHS Secretary to take steps within 180 days to revise IOR eligibility regulations, guidance and policies. The steps include requiring minimum tangible domestic assets, bonding or both, and increasing minimum bond coverage. The order also calls for an IOR to be designated and reported to CBP, with a bond or sufficient tangible domestic assets, or both, for formal and informal entries.
The Secretary is directed to take steps to revise the rules and require additional data from IORs, including anticipated import volumes, year organized, ownership and beneficial ownership, business affiliations and domestic assets. Within the same 180-day period, the Secretary is to require IORs to maintain “good standing.” CBP is to define that status based on the IOR’s and affiliates’ compliance history and payment of customs liabilities, among other considerations. An IOR that is not in good standing is to be barred from importing and from activities directly related to importation.
Within that same period, the registry is to be updated to remove inactive IORs, confirm active IORs are compliant and create risk-based tiers. Enhanced and recurrent vetting is also to cover foreign IORs, IOR affiliates, brokers, custodians of bonded merchandise and freight forwarders.
The order directs other provisions “promptly,” rather than within 180 days. It directs the Secretary to change the rules so foreign IORs, meaning those that do not meet the order’s definition of a U.S. IOR, cannot file informal entries. For formal entries, a foreign IOR may not rely on a continuous bond unless CBP permits it, and must be validated in CTPAT, if CBP determines it is eligible, or use a CTPAT validated and licensed broker. These are directed rules, not rules already in force. The order also directs heightened import disclosure and certification requirements and, within 90 days, steps to require the documentation or information the foreign exporter had to submit to its own customs administration before export.
When Do the Form 5106 and IOR Deadlines Fall?
- Order signing date: June 3, 2026. The President signed E.O. 14411.
- Order publication date: June 10, 2026. The order appeared in the Federal Register.
- Notice publication date: August 19, 2026. CBP published its Form 5106 accuracy notice.
- Enforcement start: September 18, 2026. CBP begins immediately voiding IOR numbers with inaccurate or incomplete Form 5106 data.
- Calculated 180-day deadline: November 30, 2026. This date is calculated from the order’s June 3, 2026, signing date. The order sets a 180-day period; it does not say all changes take effect on that date.
How Can Importers Keep Their IOR Number From Being Voided?
IORs should compare the Form 5106 information on file against current records and confirm every item is accurate and complete. Check the importer name, EIN, SSN or CBP-assigned number, mailing address, physical location if different, phone number and email address. Confirm that the physical location is the actual location of the business or individual and that the email address and phone number belong to the IOR.
Correct any physical address that uses a registered agent, broker, freight forwarder, P.O. box, business service center or another party’s address. Replace any third party’s phone number or email address with valid IOR contact information. Review optional company, ownership and officer information too, as CBP says it is reviewing Form 5106 information comprehensively.
Before submitting an update, the certifying party should take appropriate steps to verify the information. Brokers should confirm their power of attorney is valid and executed directly with the IOR, exercise due diligence, and avoid transmitting information they know or should know is false, misleading or unverified.
What Has CBP Not Said About IOR Voiding?
The notice does not say how long CBP’s accuracy review or a reestablishment review takes. It does not list the evidence needed to corroborate identity, leaving that to the individual voiding notice, and it does not set out an appeal process. Nor does it say whether CBP will contact an IOR before voiding a number.
The executive order directs some changes within 180 days and others “promptly,” but the notice does not provide implementing rules for the asset, bond, data, good-standing, registry or vetting requirements. The calculated November 30, 2026, deadline is not an effective date for all those requirements. Importers should distinguish the announced Form 5106 enforcement from these further actions, which still need implementation details.
Sources
- Accuracy of Importer of Record Data Submitted to CBP, U.S. Customs and Border Protection, Federal Register
- Executive Order 14411, Strengthening Customs Enforcement, The President, Federal Register
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