Check to ensure the companies you ship to in the USA have correct Importer of Record (IOR) information with Customs. This can be updated via Form 5106. Beginning September 18, 2026, US Customs and Border Protection (CBP) will void IOR 's with information that is inaccurate, incomplete or inactive.
Quick answer
What is changing for importers of record on September 18?
Beginning September 18, 2026, CBP may immediately void your importer of record number if the identity data on CBP Form 5106 is inaccurate or incomplete. A voided number cannot be used to enter merchandise into the United States. Verify your legal name, tax ID, address, phone, email, and power of attorney now, and correct any errors before the deadline.
Why this is urgent
If the information on Form 5106 is incomplete or inaccurate, CBP will immediately void the IOR number. Once voided, that number is invalid for any purpose, including entering merchandise into the United States. Now is the time to act on compliance.
Key takeaways
- Deadline: enforcement begins September 18, 2026, for new and existing importers of record.
- Trigger: inaccurate or incomplete CBP Form 5106 identity data.
- Consequence: immediate voiding of the IOR number, so no entries can be made.
- Watch your email: the voidance notice goes to the most recent email on file, so an outdated one means you may not know until it is too late.
What CBP is doing and when
On August 19, 2026, CBP published a general notice in the Federal Register announcing enhanced enforcement of importer of record (IOR) data accuracy. It applies to both new and existing IORs, and it is the first concrete implementation step of a broader enforcement program. The core mechanism is simple and severe: beginning September 18, 2026, if CBP determines that the identity data on CBP Form 5106 is inaccurate or incomplete, it may immediately void the IOR number.
- Executive Order 14411, Strengthening Customs Enforcement, is signed.
- CBP publishes its Federal Register notice announcing enhanced enforcement of Form 5106 data accuracy.
- Enforcement begins. CBP may immediately void IOR numbers with inaccurate or incomplete data.
The order behind it: Executive Order 14411
This enforcement approach stems from Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026. It directs authorities to verify active importers, remove inactive records, and make sure IORs remain compliant with customs rules and disclosures. The same order sets in motion a broader eligibility framework, still to be defined in rulemaking, that calls for:
- Good standing rules: new standards importers must meet to keep active status.
- Higher bonding or domestic asset requirements: stronger financial or tangible US-asset backing.
- More ownership disclosures: clearer identification of who is behind the importer.
- Risk tiers and recurrent vetting: ongoing, tiered review rather than a one-time check.
The September 18 Form 5106 action is the first wave. More revisions to importer eligibility rules and guidance are expected to follow.
What to check on your Form 5106
Review every identity field CBP holds for your importer of record. USCBP Form 5106
At minimum, confirm each of these is current and matches your organization directly, not a third party:
| Field | What to confirm |
|---|---|
| Legal name | Exact registered legal entity name, matching your tax records. |
| Tax ID | Correct IRS or CBP-assigned identifier tied to that legal entity. |
| Physical address | Current physical location, not a lapsed or third-party address. |
| Phone number | A working, monitored number for your organization. |
| A current, monitored inbox, because this is where a voidance notice is sent. | |
| Power of attorney (POA) | A valid POA executed directly with the broker acting on your behalf. |
Do not overlook the email
Beyond the basics, confirm the email address on file is accurate. That is who CBP notifies if the IOR number is suspended, and the notice goes to the most recent email on the Form 5106. If that email is out of date, you may be suspended and not even know it until it is too late.
What is at stake if you get this wrong
A single incorrect field can void the number that lets you import. Without a valid IOR number, you cannot make entry into the United States. The downstream consequences compound quickly:
- Rejected entries
- Stranded cargo
- Storage costs and demurrage
- Missed customer commitments
- And worst of all, potentially losing the ability to import into the United States
CBP also reminds brokers to exercise due diligence and not transmit information they know or should know is false, misleading, or unverified, and it reserves the right to pursue additional enforcement action.
How to correct your importer profile
If you find an error, correct it through the proper channel and document it:
- File the update through ABI, or by email to your assigned Center of Excellence and Expertise. If no Center is assigned, use the Center aligned to the HTSUS classification of your highest-valued commodity.
- Keep the record. Retain the submission, the date, and CBP's confirmation.
- Assess whether a correction is also an admission. If a prior certification was knowingly inaccurate, the correction itself may create exposure, so speak with customs counsel first so it is sequenced with any prior-disclosure analysis rather than filed in isolation.
Frequently asked questions
What happens on September 18, 2026?
Beginning September 18, 2026, CBP may immediately void an importer of record number if it determines that the information on CBP Form 5106 is inaccurate or incomplete. A voided number is invalid for any purpose, including entering merchandise into the United States.
What is Executive Order 14411?
Executive Order 14411, Strengthening Customs Enforcement, was signed on June 3, 2026. Section 2(e) directs the Department of Homeland Security to confirm that active importers of record comply with applicable regulations and disclosures. CBP implemented the first step through a Federal Register notice on August 19, 2026.
What information on Form 5106 do I need to verify?
Confirm your legal name, tax ID, physical address, phone number, email address, and that a valid power of attorney is on file with your broker. The email matters most, because CBP sends any voidance notice to the most recent email on the Form 5106.
What happens if my IOR number is voided?
A voided IOR number cannot be used to make entry, which can cause rejected entries, stranded cargo, storage and demurrage charges, missed customer commitments, and, in the worst case, loss of the ability to import into the United States until the record is corrected.
How do I correct my Form 5106?
Updates are filed through ABI or by email to your assigned Center of Excellence and Expertise; if none is assigned, use the Center aligned to the HTSUS classification of your highest-valued commodity. Keep the submission, the date, and CBP confirmation, and consult customs counsel first, because a correction of a prior knowing misstatement can create its own exposure.
Disclaimer: this content is for general information only and is not legal advice. Confirm your obligations with CBP or qualified customs counsel before acting.
Timothy Byrnes - Jet Worldwide
Timothy Byrnes has led Jet Worldwide, a Montreal-based international logistics, since 1988, specializing in cross-border shipping and US and Canadian trade compliance. More about our team.
