CBP Announces Enhanced Importer of Record Verification Program; Inaccurate Form 5106 Information May Result in Immediate Voiding of Importer Numbers

U.S. Customs and Border Protection (CBP) has announced enhanced enforcement procedures to verify the accuracy of Importer of Record (IOR) information submitted through CBP Form 5106. Beginning September 18, 2026, CBP may immediately void an IOR number if it determines that the information provided is inaccurate or incomplete—in effect barring the importer from entering merchandise into the United States. The new enforcement procedures follow Executive Order 14411, “Strengthening Customs Enforcement,” issued on June 3, 2026.

Overview

According to the notice, CBP is taking initial steps to implement Executive Order 14411, which directs the Department of Homeland Security to strengthen customs enforcement and confirm that active importers comply with applicable regulations and disclosure requirements. CBP adds that broader revisions to importer eligibility regulations, policies, and guidance are under development.

Under existing regulations, importers must obtain an importer identification number through submission of CBP Form 5106. The form requires information such as:

• Importer name
• Internal Revenue Service (IRS) Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned number
• Mailing address
• Physical address if different from the mailing address
• Telephone number
• Email address

Enhanced Review of Form 5106 Information

CBP states that it is conducting a comprehensive review of Form 5106 information currently on file and expects importers and customs brokers to ensure that all information is complete, accurate, and attributable directly to the importer.

The agency specifically emphasizes the following:

Physical Address Requirements

The physical address provided must reflect the importer’s actual place of business or the individual’s associated address. CBP states that the following generally are not acceptable as the importer’s physical address:

• Registered agent addresses
• Customs broker addresses
• Freight forwarder addresses
• P.O. boxes
• Business service centers
• Addresses belonging to another person or entity

Email Address Requirements

The email address must belong to the importer itself. Customs brokers and other third parties may not substitute their own email addresses or the email addresses of unrelated parties.

Phone Number Requirements

Likewise, the telephone number submitted must belong to the importer and not to a customs broker, freight forwarder, or other third party.

Broker Due Diligence Obligations

CBP reminds customs brokers that they must exercise due diligence and should not transmit information they know or should know is false, misleading, or unverified. A broker submitting Form 5106 information on an importer’s behalf must possess a valid Power of Attorney executed directly with the importer.

Immediate Consequences for Inaccurate Information

Beginning September 18, 2026, if CBP determines that Form 5106 information is inaccurate or incomplete, the agency states that it will immediately void the associated IOR number. A voided number will become invalid for any purpose, including the entry of merchandise into the United States. CBP also reserves the right to pursue additional enforcement actions.

The notice further warns that inaccurate information may expose importers and associated individuals to consequences under:

• Federal false statement statutes
• The False Claims Act
• Customs broker penalty provisions, where applicable

Procedure for Voided Importer Numbers

If CBP voids an IOR number, the agency will issue written notice to the email address most recently provided by the importer. The notice will explain the basis for the action and provide instructions for seeking reestablishment of the importer number. Where appropriate, CBP may also copy the customs broker that most recently filed entry on behalf of the importer.

What This Means for Importers and Customs Brokers

This announcement signals a more aggressive importer verification posture by CBP and appears designed to address concerns regarding shell entities, nominee structures, and inaccurate importer identification data. Companies that have historically relied on brokers, freight forwarders, registered agents, or other third parties to supply contact information should review their importer records carefully.

Importers should consider:

• Conducting an immediate audit of all Form 5106 information on file with CBP
• Confirming that physical addresses, phone numbers, and email addresses belong directly to the importer
• Verifying that EIN, SSN, and ownership information are current and accurate
• Reviewing broker Powers of Attorney to ensure compliance with CBP requirements
• Establishing internal procedures for maintaining current importer information
• Identifying any import activity that could be disrupted if an IOR number is suspended or voided

Looking Ahead

CBP expressly notes that additional importer eligibility regulations, policies, and guidance may be forthcoming as the agency continues implementation of Executive Order 14411. Importers should expect increased scrutiny of importer registration information and prepare for additional compliance requirements in the months ahead.

Bottom Line

The new CBP enforcement initiative substantially raises the stakes for maintaining accurate importer registration information. Companies engaged in importing goods into the United States should review their Form 5106 records before the September 18, 2026 enforcement date to minimize the risk of business disruption, entry delays, or loss of importer privileges.

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202.640.6680)
• Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202.230.9889)
• Aristeo Lopez (alopez@clarkhill.com; 202.552.2366)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• Laura M. Quesada (Lquesada@clarkhill.com; 202.240.0170)
• Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
• Onjoly Purification (Opurification@clarkhill.com; 202.552.2361)

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