CBP Will Void Importer of Record Numbers Over Form 5106 Errors Starting September 18

CBP is reviewing the Form 5106 record of every importer of record on file. From September 18, 2026, a record CBP finds inaccurate or incomplete can have its IOR number voided. No new data elements, and a hard date.

CBP published a Federal Register notice on August 19, 2026 saying it is reviewing the CBP Form 5106 information on file for importers of record (91 FR 53627). Beginning September 18, 2026, if CBP finds that a record is inaccurate or incomplete, it will void that importer's IOR number. A voided number is invalid for any purpose, including entering merchandise.

This is not a new filing requirement. The Form 5106 data elements have not changed, and the duty to keep them accurate was already there. The change is that CBP is checking the records it already holds, and that an inaccurate one now carries a specific consequence with a date on it.

What CBP is checking

The Form 5106 requires six data elements: importer name; EIN, SSN, or CBP-assigned number; mailing address; physical location address if it differs; phone number; and email address (19 CFR § 24.5). The notice adds none of its own. It singles out three that CBP says must belong to the importer itself.

• Physical address: the actual physical location of the business or individual. A registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, or another party's address does not qualify.
• Email address: valid, and belonging to the importer. A broker or third party may not substitute its own address or someone else's.
• Phone number: valid, and belonging to the importer. A broker's or forwarder's number in place of the importer's is not acceptable.

The third-party substitution is the one worth a close look. Listing a broker's or forwarder's address, email, or phone on a client's record has been a routine convenience, often so that correspondence reaches someone who will read it. CBP is saying plainly that it makes the record inaccurate.

What was already required, and what changed

The accuracy obligation is not new, and neither is the exposure behind it. A broker preparing or filing your Form 5106 must exercise due diligence (19 CFR § 111.29(a)). It must not give CBP information it knew or should have known was false or misleading (19 CFR § 111.32). Your broker must also hold a power of attorney executed directly with you, not through a freight forwarder or other third party (19 CFR § 111.36(c)(3)).

The party certifying the form carries its own statutory exposure. CBP's notice points to fines or imprisonment under 18 U.S.C. § 1001 for an intentional false statement, and to False Claims Act liability, on the reasoning that importer identity bears on the obligation to pay duties.

The enforcement step is the new part. CBP says it is comprehensively reviewing the records on file, and that from September 18 it will void the number of an importer whose information it finds inaccurate or incomplete. Other enforcement actions are possible as well.

CBP frames this as an initial step toward implementing Executive Order 14411. It points to the section directing DHS to confirm that active importers of record are compliant with applicable regulations and disclosures (§2(e)). The rest of the EO, including the CTPAT and continuous bond changes previewed for foreign importers, is still unwritten and carries no compliance date.

AP Customs is not currently CTPAT validated. CBP's announced foreign-IOR requirements are still being implemented, and no compliance dates have been set. We are monitoring CBP's implementation and can help businesses understand current customs requirements and prepare for the announced changes.

The notice goes to the email address on file

If CBP voids a number, it sends a written notice to the email address the importer most recently submitted, explaining the basis for the action. If a broker filed the last entry for that importer, CBP copies the broker. The notice explains how to ask for the number to be reestablished and what CBP needs in order to confirm who is asking.

The record CBP is enforcing is also the record it uses to reach you. An importer whose email address is out of date, or belongs to a third party, is both the most likely to be voided and the least likely to hear about it. Your broker may find out first, and only if it filed your last entry.

What to check before September 18

All of this is verifiable today and none of it waits on further CBP guidance.

• Pull your current Form 5106 record and read what is on it. Ask your broker for what was transmitted, not what was intended.
• Confirm the physical address is your own operating location, not a registered agent, broker, forwarder, P.O. box, or mail service.
• Confirm the email address and phone number reach you directly, and that neither belongs to a broker, forwarder, or other third party.
• Check the legal name and the EIN, SSN, or CBP-assigned number against your incorporation and IRS records. A name that changed after registration is a mismatch.
• Confirm your broker's power of attorney was executed directly with you. One that came through a forwarder does not meet § 111.36(c)(3).

If something is wrong, correct it now. A Form 5106 update filed before September 18 is routine. The same correction after a void becomes a reestablishment request, with your IOR number unusable while you wait.

What CBP has not said

The notice does not publish the criteria CBP will use to decide that a record is inaccurate or incomplete, how far back the review reaches, or how long a reestablishment takes. It also does not describe any warning before a void, since the written notice follows the action. Questions and reestablishment requests go to IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy."

Not sure what CBP has on file for you?

This article is general information for importers, NVOCCs, and freight forwarders and is not legal advice. CBP's August 19, 2026 general notice is published and its enhanced enforcement begins September 18, 2026. Specific situations should be confirmed against current CBP guidance and reviewed with qualified counsel and a licensed customs broker.