CBP Will Void Importer of Record Numbers Beginning September 18, 2026

What Every Importer and Customs Broker Must Verify on CBP Form 5106 in the Next 30 Days

CBP published a federal register notice on August 19, 2026 announcing that, beginning September 18, 2026, it will immediately void importer of record numbers when the information on CBP Form 5106 is inaccurate or incomplete. A voided IOR number is invalid for every purpose, including making entry, which means cargo stops at the port with no advance warning. This article explains what CBP is verifying, why several long-accepted industry practices are now defects, and the corrective steps importers and brokers should take before the enforcement date.

KEY TAKEAWAYS

Effective September 18, 2026, CBP will void importer of record (IOR) numbers where the information on CBP Form 5106 is inaccurate or incomplete. A voided number cannot be used for any purpose, including making entry.
The physical address on file must be the actual location of the business or individual. A registered agent, customs broker, freight forwarder, P.O. box, business service center, or any other party’s address is now a defect.
The email address and phone number must belong to the IOR. Broker or forwarder contact information in those fields no longer passes.
Customs brokers must hold a power of attorney executed directly with the IOR, not routed through a freight forwarder or other third party.
Exposure extends past the voided number. CBP cites 18 U.S.C. § 1001, the False Claims Act at 31 U.S.C. § 3729 et seq., and broker penalties under 19 U.S.C. § 1641.
CBP will send the voiding notice to the email address most recently submitted by the IOR. If that address is wrong, the importer may not learn of the voiding until cargo stops moving.

CBP is moving from data collection to data enforcement

On June 3, 2026, President Trump signed Executive Order 14411, Strengthening Customs Enforcement. Section 2(e) directs the Secretary of Homeland Security to confirm that active importers of record are compliant with all applicable regulations and disclosures. The general notice is CBP’s first concrete implementation step, and it is more aggressive than many expected.

CBP states that it is comprehensively reviewing the CBP Form 5106 information on file for all importers of record. Beginning September 18, 2026, if CBP determines that an IOR, or a customs broker acting on the IOR’s behalf, failed to provide complete and accurate information, CBP will void the IOR number and may take other enforcement action as appropriate.

The scale of this review should not be underestimated. Earlier this year, CBP deactivated roughly 4.8 million importer of record accounts that had not filed an entry within the preceding year. The agency is working through the IOR registry systematically, not case by case.

Data Elements on Form 5106 MUST be Correct

The notice states that CBP is implementing enhanced enforcement measures to ensure the accuracy of information provided. They identify three data elements in particular that must be provided completely and accurately:

Physical address. It must be the actual physical location of the business or individual. CBP expressly excludes a registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, and the address of any other person or entity. The Form 5106 instructions do permit a principal’s home address to serve as the address associated with the business.
Email address. It must be valid and belong to the IOR. A broker or third party may not substitute its own email address or the address of another entity.
Phone number. It must be valid and belong to the IOR. Numbers not associated with the IOR should not be submitted.

Consider who this actually captures. Non-resident importers that listed a U.S. broker’s address because they have no U.S. premises. Delivered duty paid arrangements where the foreign seller is the IOR and the forwarder’s contact details populate the record. E-commerce sellers using a third-party fulfillment center address. Small importers whose accountant or registered agent completed the form years ago and never revisited it. Every one of these records is now exposed.

The notification problem

CBP will issue written notice of the voiding to the email address the IOR most recently submitted to CBP. If applicable, CBP will copy the customs broker that last filed an entry on the IOR’s behalf. Read that alongside the requirement that the email address belong to the IOR and the circularity becomes clear. The importers most likely to have a defective email address on file are precisely the importers least likely to receive the notice telling them their number has been voided.

There is no pre-deprivation process described in the notice. CBP does not propose to issue a request for information, allow a cure period, or provide a hearing before voiding. The action comes first. Reestablishment comes after, on a timeline CBP has not published, through an email inbox at IORProgram@cbp.dhs.gov using the subject line “Enforcing IOR Accuracy.”

The liability does not stop at a voided number

CBP frames inaccurate Form 5106 data as material to an obligation to pay money to the government. That framing is deliberate and consequential.

The certifying party may face fines or imprisonment under 18 U.S.C. § 1001 for an intentional false statement.
CBP states that inaccurate or misleading Form 5106 information is material to an obligation to pay money to CBP and could create liability under the False Claims Act, 31 U.S.C. § 3729 et seq. That statute carries treble damages and qui tam exposure.
Customs brokers face due diligence obligations under 19 CFR 111.29(a), the prohibition on transmitting false or misleading information under 19 CFR 111.32, and monetary penalties under 19 U.S.C. § 1641.
Brokers must execute the power of attorney directly with the IOR under 19 CFR 111.36(c)(3). A POA obtained through a freight forwarder does not satisfy the regulation.

For brokers, the practical exposure is broader than for any single importer. A brokerage that populated its own address, email, or phone across hundreds of client records has hundreds of potential defects, each of which CBP now treats as unverified information transmitted to the agency.

What Importers and Brokers Should Do

The enforcement date is fixed and the corrective window is short. The following sequence should be completed before September 18, 2026.

Pull the actual data on file. Do not rely on what you believe was submitted. Request the current Form 5106 record through your customs broker or the ACE Secure Data Portal and review the physical address, mailing address, email address, phone number, and identification number as CBP sees them today.
Test each field against the disqualifiers. For the physical address, ask whether an officer visiting that location would find your business operating there. If the answer involves a mail service, a registered agent, a lawyer, an accountant, a broker, a forwarder, or a warehouse operated by someone else, the field needs to change.
Assign an owned, monitored email address. This is the single highest-value fix, because it is also the channel through which CBP will tell you something has gone wrong. Use a domain the importer controls and a mailbox a compliance-responsible employee actually reads, not an individual who may leave the company.
Audit powers of attorney. Brokers should confirm that every active POA was executed directly with the IOR and that the signer had authority to bind the entity. POAs obtained through a forwarder should be re-executed now, not after CBP asks.
Re-examine non-resident and DDP structures. A foreign entity acting as IOR without a U.S. physical location faces a structural problem, not a data-entry problem. That analysis should be run against the broader eligibility framework Executive Order 14411 sets in motion, including bonding, tangible domestic asset, and good standing requirements still to be defined in rulemaking.
Correct through the proper channel and document it. Updates are filed via ABI or by email to the assigned Center of Excellence and Expertise. If no Center has been assigned, use the Center aligned to the HTSUS classification of the highest valued commodity. Retain the submission, the date, and CBP’s confirmation.
Evaluate whether a correction is also an admission. If a prior certification was knowingly inaccurate, the correction itself may create exposure under 18 U.S.C. § 1001 or the False Claims Act. Speak with customs counsel before filing so the correction is sequenced with any prior disclosure analysis rather than made in isolation.
Calendar recurring verification. Treat Form 5106 accuracy as a standing compliance control with an owner and a review date, not a one-time registration task. Address changes, entity restructurings, and personnel departures all break the record.

Importers that complete this review before September 18, 2026 keep their IOR numbers active and their entries moving while competitors sort out voided records, held cargo, demurrage, and general order exposure. Accurate Form 5106 data also removes a straightforward point of attack in any future penalty case, where CBP or the Department of Justice would otherwise be able to point to a defective certification as evidence bearing on reasonable care and culpability.

Brokers that complete a portfolio-wide POA and contact-data audit convert a latent 19 U.S.C. § 1641 exposure into a documented due diligence record. That record is what distinguishes a brokerage that transmitted unverified information from one that exercised the diligence the regulations require.

Importers that do nothing will find out that their number was voided when a broker cannot file an entry, and they will then be negotiating reestablishment with CBP from a position of operational emergency, with cargo accruing costs at the port and no published timeline for resolution.

How Diaz Trade Law Can Help

Diaz Trade Law represents importers and customs brokers in CBP enforcement matters, including penalties, seizures, audits, prior disclosures, and broker compliance. We regularly conduct importer of record readiness reviews, evaluate foreign IOR and DDP structures, audit power of attorney portfolios, and advise on whether a correction should be paired with a prior disclosure under 19 U.S.C. § 1592.

If you are unsure what CBP currently has on file for your company, that uncertainty is itself the risk. Contact Diaz Trade Law at 305-456-3830 or info@diaztradelaw.com to schedule a Form 5106 review before the September 18, 2026 enforcement date.

Related Reading from Diaz Trade Law

CBP Will Void Importer of Record Numbers Beginning September 18, 2026