Beginning tomorrow, September 18, 2026, U.S. Customs and Border Protection (CBP) may immediately void an importer of record (IOR) number if it determines the information on that importer's CBP Form 5106 is inaccurate or incomplete. A voided IOR number means you cannot enter merchandise into the United States. If you have not looked at your Form 5106 in the last year or two, today is the day to look at it — and the single most useful thing you can check is whether the address, email, phone number, and tax ID on file are actually yours and actually still live.
What CBP Actually Published
The authority comes from a CBP general notice, "Accuracy of Importer of Record Data Submitted to CBP," published in the Federal Register on August 19, 2026 at 91 FR 53627–53628 (document 2026-16911). The same notice was reprinted in the Customs Bulletin, Vol. 60, No. 26, dated September 2, 2026.
The operative sentence is short and leaves little room to read around it: "This enhanced enforcement, including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026."
The notice implements Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026. CBP's own page for that order states the underlying obligation plainly: "Importers of Record (IORs) and licensed customs brokers, acting on their behalf, are required to ensure that information submitted on the CBP Form 5106 is accurate, complete, and updated as needed." It also states that "CBP may immediately void an associated IOR number and take other appropriate enforcement actions if CBP determines that the CBP Form 5106 information is inaccurate or incomplete."
Two words in that sentence are doing most of the work. "Immediately" means the notice does not describe a warning letter, a cure period, or a 30-day window to fix the record before the number stops functioning. And "incomplete" means this is not only about affirmatively false data — a blank or abandoned field is inside the stated scope.
What Form 5106 Is, and Why It Is Suddenly Load-Bearing
CBP Form 5106 is the "Create/Update Importer Identity Form" — the record that establishes who you are in CBP's systems and ties your importer of record number to a real legal entity with a real address and a real tax identification number. For most importers it is a form filled out once, at onboarding, often by whoever set up the customs relationship, and then never opened again.
That is exactly the problem this enforcement action is built around. A Form 5106 is a snapshot of an importer as it existed on the day someone typed it in. Companies move offices, change phone systems, get acquired, change tax IDs after a restructuring, and lose the employee whose email address went in the contact field. None of those events generate a notice to CBP on their own. The record simply drifts out of true while entries keep clearing normally — right up until an enforcement posture changes.
As of September 18, 2026, that drift is enforceable.
The Five Elements That Must Be Yours — Not Your Broker's
The notice is specific about whose information belongs in these fields, and it is worth stating exactly, because this is where a large number of otherwise well-run import programs are quietly out of compliance. Per 91 FR 53628, the following must belong to the importer of record itself — not to the customs broker, not to a registered agent, not to any other third party:
- Physical address
- Email address
- Phone number
- IRS Employer Identification Number (EIN)
- Social Security Number (SSN), where the importer files under one
Read that list against how customs onboarding actually happens in practice. It is extremely common for a broker to file the 5106 on a new client's behalf and, for convenience, put the broker's own office address in the address field, the broker's mailbox in the email field, and the broker's switchboard in the phone field — because the broker is the party who will actually be fielding CBP correspondence. For years that was a workflow shortcut with no visible consequence. The same is true of foreign importers of record using a U.S. registered agent's address as their address of record, and of small importers whose 5106 carries the address of an accountant, a fulfillment partner, or a 3PL.
Under this notice, each of those is third-party information sitting in a field that the notice says must carry the importer's own. If you inherited your 5106 from a broker relationship you have since ended, assume nothing about what is in those fields until you have seen them.
The Trap: The Notice Goes to the Email on File
This is the part that deserves more attention than it is getting, because the failure mode is self-concealing.
Under the notice, when CBP voids an IOR number it sends written notice of the action to "the email address the IOR most recently submitted to CBP." CBP may also copy the customs broker who last filed an entry for that importer.
Now sit with the circularity. The most common defect this enforcement targets is a stale or third-party email address. And the delivery mechanism for the consequence is that same email address. If the address in your 5106 belongs to an employee who left in 2023, or to a broker you stopped working with, or to an alias nobody monitors, then the one notification CBP sends about your voided number lands somewhere you will never see it.
In that scenario you do not learn your IOR number was voided when CBP tells you. You learn it when a shipment stops — when a filing rejects, when a container sits, when your broker calls to ask why the entry will not go through. By then you are paying for the consequence and the diagnosis at the same time, with demurrage, per diem, or storage running underneath both.
A bad email address is the one error on this form that hides its own consequence. That is why it is the first field to check, not the last.
Who Is Most Exposed
If you are triaging where to spend the next hour, these are the profiles most likely to have a problem:
Importers who have not touched the 5106 in years. This is the single strongest predictor. The longer the record has sat, the more corporate change has accumulated behind it. An importer who has filed continuously since 2019 without ever updating the form has had six years of opportunity for the record to go stale.
Importers who changed brokers. If the old broker filed your 5106 and populated it with their own contact data, ending the relationship did not update the form. The fields still point at a firm with no reason to forward your mail.
Foreign importers of record. If your U.S. presence runs through a registered agent, look carefully at whether the agent's address and contact details ended up in fields the notice says must be the IOR's own.
Entities that restructured, merged, or changed tax IDs. A new EIN after a reorganization is precisely the kind of change that makes the number on file inaccurate rather than merely stale.
New importers who came in through the de minimis collapse. A large cohort of businesses became importers of record for the first time after the $800 exemption was suspended in June 2026 — many of them filled out a 5106 quickly, under pressure, to keep parcels moving. We wrote about that transition in our guide to the de minimis suspension; if you were in that group, your 5106 was built in a hurry and is worth a second read.
What To Do Today
This is a short list and it is genuinely doable in one sitting.
1. Pull your current 5106 data and read it field by field. Do not rely on memory of what was submitted, and do not rely on a summary. Look at the actual address, email, phone, and EIN or SSN on file.
2. Test the email address. Send mail to it from an outside account and confirm a human being at your company receives it. An address that bounces is a problem; an address that silently delivers to an unmonitored mailbox is a worse one, because it looks fine from the outside.
3. Test the phone number. Call it. Confirm it rings somewhere your company answers.
4. Confirm the address is your physical location. Not your broker's. Not your agent's. Not a mail drop.
5. Confirm the EIN matches your current IRS registration exactly. Digit by digit, against a current IRS document — not against what someone believes it to be.
6. If anything is wrong, file an updated 5106. The form exists to be updated; CBP's own guidance frames the obligation as keeping the information "accurate, complete, and updated as needed." Correcting a record before it is challenged is a categorically better position than correcting it after.
7. Put it on a recurring calendar. Annual, or at any corporate change — new office, new EIN, departure of the person in the contact field, change of broker. This form should never again be a six-year-old artifact.
If your compliance program has never assigned an owner to the 5106, assign one now. The form has no natural review trigger, which is exactly why it rots. Our compliance consulting practice treats importer identity data as part of the standing compliance file for that reason, alongside classification, valuation, and origin documentation.
If Your Number Is Voided
The notice provides a path. The importer of record, or a customs broker authorized to act on its behalf, may request reestablishment of a voided IOR number by contacting CBP at the email address given in the voidance notice.
Two honest caveats. First, that is a request, not an entitlement: the notice describes a procedure for asking, and we are not going to tell you what CBP will decide or how long it will take, because nobody outside the agency knows that. Second, the request procedure runs through the notice itself — which means an importer who never received the notice, because the email on file was bad, is starting the remedy process from further back than one who did.
That asymmetry is the whole argument for checking the record today rather than after something breaks.
The Penalty Language Is Not Decoration
The notice also carries a warning that is easy to skim past. It states that inaccurate or misleading Form 5106 information is material to an obligation to pay money to CBP, and that submitting it may expose the importer of record or associated individuals to penalties under 18 U.S.C. 1001 and to liability under the False Claims Act.
That framing matters. It moves the 5106 out of the category of administrative housekeeping and into the category of statements made to the government in connection with money owed — the same category as the entry data itself. An importer who discovers a wrong EIN on the form and leaves it there is not tidying a stale record at that point; they are on notice.
We have written before about how correction mechanisms work once an error is identified on the entry side, in our post-summary correction guide. The instinct is the same here: find it yourself, fix it yourself, and document when you did.
Yes. The obligation attaches to the importer of record, and the IOR number CBP may void is yours, not your broker's. A broker filing on your behalf is also covered by the accuracy requirement, but the enforcement consequence — inability to enter merchandise — lands on you. A broker relationship is a reason to coordinate on this today, not a reason to assume it is handled.
My broker's address is on my 5106 because that is how we set it up. Is that a violation?
The notice is explicit that the physical address, email address, phone number, EIN, and SSN must belong to the importer of record and not to the customs broker, a registered agent, or another third party. We are not in a position to tell you how CBP will treat any individual record, and we will not guess. What we can say is that this configuration is squarely inside what the notice describes as the target, and it is straightforward to correct by filing an updated form.
What happens to merchandise already in transit if my IOR number is voided?
A voided IOR number means the importer cannot enter merchandise into the United States. Goods in transit do not stop being your problem — they arrive, and they need an entry that cannot be filed under a voided number. Costs accrue while the situation is unresolved. That is the practical case for checking the record before a shipment is riding on it.
Is there a grace period after September 18, 2026?
The notice does not describe one. It says enhanced enforcement, "including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026." As of today, September 17, 2026, we have seen nothing from CBP delaying, staging, or phasing that date. If that changes, the notice's own terms are what will have changed, and this article will need an update.
Check the Record Before a Shipment Rides On It
An hour spent reading your own Form 5106 today is the cheapest compliance work available to you this week. The importers most likely to be caught by this are not the careless ones — they are the ones whose paperwork was correct when it was filed and has been quietly aging ever since.
Here is how we help:
- Clear — we file entries at all U.S. ports as your licensed broker, at $100–$250 per entry depending on complexity, which includes coordinating on the identity data those entries depend on.
- Consult — we will sit down with your 5106 and your corporate records and tell you where they disagree, without telling you what CBP is going to do about it.
- Comply — we build importer identity into a standing compliance file with a named owner and a review cadence, so the form stops being a six-year-old artifact.
- Automate — our self-filing platform puts entry filing in your hands at $30 per entry, with licensed broker support when a filing gets complicated.
If you are not sure what is on your Form 5106, or you know it is wrong and want help correcting it, talk to our team. We are in Bozeman, Montana, and we answer the phone Monday through Friday, 6:00 AM to 6:00 PM Mountain Time.