CBP is voiding IOR numbers for inaccurate Form 5106 data: what to fix now

On August 19, 2026, CBP published a Federal Register notice that turns Form 5106 accuracy into an immediate operational risk. Beginning September 18, 2026, CBP can void an Importer of Record (IOR) number when the data on file is inaccurate or incomplete. A voided IOR is invalid for any purpose, including entry.

This is not a theoretical cleanup project. If your physical address is a broker office, a registered agent, a freight forwarder, a P.O. box, or a service center, or if the email and phone on file belong to someone other than the IOR, you are in the enforcement window CBP just opened.

A voided IOR number is invalid for any purpose, including entering merchandise into the United States.

Why CBP is doing this now

The notice implements Executive Order 14411, Strengthening Customs Enforcement (signed June 3, 2026; published at 91 FR 35125). Section 2(e) directs DHS to confirm that active IORs comply with applicable regulations and disclosures. CBP's August 19 notice is the first public enforcement step on Form 5106 accuracy.

CBP frames the authority against 19 U.S.C. §§ 1484 and 4320, and the importer-identification process in 19 CFR § 24.5. The Create/Update Importer Identity Form (CBP Form 5106) is how an individual or entity obtains an IOR number to make entry or request services that create a bill or refund.

Required Form 5106 elements CBP will test

To obtain or maintain an IOR number, the Form 5106 must include these required elements:

• Importer name
• IRS EIN, SSN, or CBP-assigned number
• Mailing address
• Physical location address, if different from the mailing address
• Phone number
• Email address

The form also has optional fields (company structure, beneficial ownership, officers). CBP's enforcement notice focuses on accuracy of the identifying data that belongs directly to the IOR, not on optional enrichment.

Physical address, email, and phone: the hard lines

CBP is explicit about what fails review:

• Physical address: must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or entity. Form instructions allow a principal's home address when that is the address associated with the business.
• Email: must be valid and belong to the IOR. Brokers and third parties may not substitute their own email, or anyone else's, for the IOR's email.
• Phone: must be valid and belong to the IOR. Brokers and third parties may not substitute their own number, or anyone else's.

What brokers must do under Part 111

Customs brokers submitting Form 5106 on a client's behalf need a valid power of attorney executed directly with the IOR, not through a freight forwarder or other intermediary, under 19 CFR § 111.36(c)(3). Brokers must exercise due diligence under 19 CFR § 111.29(a), and must not transmit information they know or should know is false or misleading under 19 CFR § 111.32.

The certifying party can face consequences under 18 U.S.C. § 1001 for intentional false statements. Inaccurate IOR data can also create False Claims Act exposure because IOR identity is material to duty liability. Brokers transmitting inaccurate Form 5106 data may face broker penalties under 19 U.S.C. § 1641.

How voiding and reestablishment work

As of September 18, 2026, if CBP determines Form 5106 information is inaccurate or incomplete, it will immediately void the associated IOR number. CBP will send written notice to the email address the IOR most recently submitted to CBP, stating the basis for the void. Where applicable, CBP may copy the customs broker that last filed entry for that IOR.

The notice will explain how to request reestablishment and what identity corroboration CBP needs. Questions and reestablishment requests go to IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy". CBP's contact for the program is Anita Rivera, Branch Chief, Revenue Enforcement Branch, at (771) 233-2939.

What to do this week

• Pull the Form 5106 / ACE importer identity record for every active IOR you file under.
• Confirm physical address is the IOR's actual location, not agent, broker, forwarder, P.O. box, or service center.
• Confirm email and phone belong to the IOR and that someone at the IOR monitors that inbox.
• Confirm the broker POA is direct with the IOR under § 111.36(c)(3).
• Update Form 5106 via ABI or the assigned Center before September 18, 2026 if anything is stale.
• If you receive a void notice, reply through IORProgram@cbp.dhs.gov with the required identity corroboration; do not keep filing on the voided number.

CBP's Strengthening Customs Enforcement page collects related EO 14411 implementation items, including this Form 5106 accuracy notice. Treat the September 18 date as live. A clean drawback claim or entry summary does not help if the IOR itself has been voided.

This article is for general information and is not legal or tax advice. Drawback eligibility depends on your specific facts, and final refunds are determined by CBP at liquidation. Consult a licensed customs broker or attorney for your situation.