August 19, 2026
CBP to Intensify Importer of Record Verification Effective September 18, 2026
U.S. Customs and Border Protection (CBP) has announced enhanced enforcement procedures to verify Importer of Record (IOR) information submitted through CBP Form 5106. The changes implement Executive Order 14411, "Strengthening Customs Enforcement," and are expected to take effect on September 18, 2026, 30 days after publication of the Federal Register notice.
Key Change
Beginning September 18, 2026, CBP may immediately void an Importer of Record number if Form 5106 information is determined to be incomplete, inaccurate, or misleading. A voided IOR number will be invalid for all customs purposes, preventing the importer from legally entering goods into the United States until reinstatement is approved.
CBP Verification Focus Areas
CBP will closely review:
Importers should note:
Potential Consequences
In addition to the immediate loss of importing privileges, inaccurate or false Form 5106 information may expose importers and related parties to:
Reinstatement Process
If an IOR number is voided, CBP will send a notification to the email address on file, with a copy to the customs broker, if applicable. The notice will outline the steps required to verify identity and request reinstatement.
Questions and reinstatement requests should be directed to:
[email protected]
Recommended Actions for Importers
Importers should immediately:
Looking Ahead
This initiative is the first of several anticipated CBP actions under Executive Order 14411. Additional requirements expected later in 2026 may include enhanced importer vetting, "good standing" requirements, increased bonding obligations, expanded importer data submissions, and risk-based importer classifications.
Bottom Line: Importers should review and update their Form 5106 information now to avoid business disruptions, shipment delays, and potential enforcement actions when CBP's enhanced verification program becomes effective.
We will keep you updated as we receive information. Please contact us if you have any questions about this or any other trade matter.
Key Change
Beginning September 18, 2026, CBP may immediately void an Importer of Record number if Form 5106 information is determined to be incomplete, inaccurate, or misleading. A voided IOR number will be invalid for all customs purposes, preventing the importer from legally entering goods into the United States until reinstatement is approved.
CBP Verification Focus Areas
CBP will closely review:
- Physical business address
- Email address
- Telephone number
- Employer Identification Number (EIN)
- Social Security Number (SSN), where applicable
Importers should note:
- The physical address must be the importer's actual business or residential location and cannot be a customs broker, freight forwarder, registered agent, or P.O. Box.
- Email addresses and phone numbers must belong directly to the importer.
- Customs brokers must have a valid Power of Attorney and perform due diligence when submitting Form 5106 information on behalf of clients.
Potential Consequences
In addition to the immediate loss of importing privileges, inaccurate or false Form 5106 information may expose importers and related parties to:
- Criminal penalties under 18 U.S.C. § 1001 for false statements
- Liability under the False Claims Act
- Customs enforcement actions and penalties
- Broker penalties under 19 U.S.C. § 1641
Reinstatement Process
If an IOR number is voided, CBP will send a notification to the email address on file, with a copy to the customs broker, if applicable. The notice will outline the steps required to verify identity and request reinstatement.
Questions and reinstatement requests should be directed to:
[email protected]
Recommended Actions for Importers
Importers should immediately:
- Review current Form 5106 records on file with CBP.
- Verify business addresses, EINs, phone numbers, and email addresses.
- Ensure all contact information belongs directly to the importer.
- Confirm Powers of Attorney with customs brokers are current and valid.
- Correct discrepancies before the September 18, 2026 implementation date.
Looking Ahead
This initiative is the first of several anticipated CBP actions under Executive Order 14411. Additional requirements expected later in 2026 may include enhanced importer vetting, "good standing" requirements, increased bonding obligations, expanded importer data submissions, and risk-based importer classifications.
Bottom Line: Importers should review and update their Form 5106 information now to avoid business disruptions, shipment delays, and potential enforcement actions when CBP's enhanced verification program becomes effective.
We will keep you updated as we receive information. Please contact us if you have any questions about this or any other trade matter.
