U.S. Customs and Border Protection (CBP) is enforcing stricter importer of record (IOR) data accuracy requirements submitted on CBP Form 5106 under Executive Order (EO) 14411, signed June 3, 2026. Beginning September 18, 2026, CBP may void IOR numbers having inaccurate or incomplete data.
On August 19, 2026, CBP published a general notice in the Federal Register announcing enhanced enforcement of IOR data accuracy. The notice is one of the first concrete implementation steps of EO 14411 and applies to both new and existing IORs.
If your CBP Form 5106 data is out of date, incomplete, or associated with a third party rather than your organization directly, your IOR number is at risk. Here’s what the enforcement covers, where importers commonly fall short, and what you can do to stay compliant.
What does CBP Form 5106 require, and what’s now being enforced?
CBP Form 5106 is the create/update importer identity form. To obtain an IOR number and make entry into the United States, every importer must complete and submit this form. The six required data elements are:
- Importer name
- Internal Revenue Service (IRS) Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned number
- Mailing address
- Physical location address (if different from mailing address)
- Phone number
- Email address
Under the enhanced enforcement measures, CBP will be strictly enforcing the requirement that every one of these elements be accurate, complete, current, and belong directly to the IOR.
CBP’s notice makes clear that it’s conducting a comprehensive review of Form 5106 data on file for all IORs, not just new filings. Where CBP finds inaccuracies, the IOR number may be voided immediately. A voided IOR number is invalid for any purpose, including entering goods into the United States.
If voiding occurs, CBP will notify the affected IOR by email at the address most recently submitted to CBP and will copy the customs broker that last filed on the IOR’s behalf. The notice will include instructions for requesting reestablishment of the IOR number.
The most common CBP Form 5106 data accuracy issues importers should review:
CBP’s notice specifically calls out three areas where inaccurate data frequently appears on Form 5106.
Physical address. The physical address must be the actual physical location of the business or individual. It cannot be a registered agent’s office, a customs broker’s address, a freight forwarder’s address, a P.O. box, or a business service center. CBP has been explicit: the address must be associated with the IOR itself.
Email address. The email address on file must be valid and belong to the IOR. Customs brokers and third parties can’t substitute their own email address in place of the IOR’s.
Phone number. The phone number must be valid and belong to the IOR. Numbers not directly associated with the IOR (including a broker’s or freight forwarder’s number) don’t meet the standard.
These may seem like straightforward requirements, but in practice, many Form 5106 filings on record don’t meet them. Brokers who submitted forms on behalf of clients may have used their own contact details. Addresses may reflect where a service provider operates rather than where the IOR is actually located. These are the types of scenarios CBP is now flagging for increased enforcement.
What about customs brokers?
Customs brokers submitting Form 5106 on an importer’s behalf must hold a valid power of attorney (POA) executed directly with the IOR (not through a freight forwarder or other intermediary).
Brokers who submit inaccurate or unverified information can face penalties under 19 U.S.C. 1641. Intentional false statements on the form could also expose parties to liability under the False Claims Act or 18 U.S.C. § 1001. Both importers and brokers have reason to review their current filings carefully.
How does this fit within the broader compliance environment?
The CBP Form 5106 enforcement doesn’t exist in isolation. It’s one piece of a broader shift in how customs compliance is being approached under EO 14411.
Among EO 14411’s wider provisions, and based on the final requirements of future enforcement implementations, importers may be required to maintain a minimum level of tangible domestic assets and bonding, disclose beneficial ownership and business affiliates, and maintain “good standing” with CBP. The EO also calls for risk-based tiering of IORs based on compliance history and audit results, enhanced vetting of customs brokers and freight forwarders, and toughened penalty structures – including a minimum penalty floor of at least 50% of the assessed penalty, with no mitigation available for repeat offenders.
What practical steps can importers take to review and update their IOR data?
The enforcement deadline is immediate. Here are the priority actions for compliance teams.
Verify your CBP Form 5106 information now. Pull your Form 5106 data on file and check every required field. Confirm the physical address is your actual business location: not a broker’s address, a P.O. box, or a service center. Confirm that the email address and phone number belong directly to your organization. If anything is out of date or incorrect, update it before CBP flags it.
Review your power of attorney with your customs broker. Your broker needs a valid POA executed directly with your organization, not through a freight forwarder or other intermediary. Confirm that it’s in place and current.
Make sure your IOR data is current. CBP’s Form 5106 accuracy enforcement is active. The steps required are specific and time-sensitive: verify your IOR data and confirm your broker’s POA.
Frequently asked questions
What is CBP Form 5106 and why does it matter?
CBP Form 5106 is the create/update importer identity form. Every importer must submit it to obtain an IOR number, which is required to make entry into the United States. The form captures the importer’s name, tax identification, mailing address, physical address, phone number, and email address.
When does CBP’s enhanced IOR enforcement take effect?
CBP’s enhanced enforcement began 30 days after the notice was published in the Federal Register on August 19, 2026, making the effective date September 18, 2026.
What happens if CBP voids my IOR number?
A voided IOR number is immediately invalid for any purpose, including entering goods into the United States. CBP will notify the affected IOR by email and copy the customs broker that last filed on the IOR’s behalf. The notice will include instructions for requesting reestablishment of the IOR number. Questions can be directed to [email protected].
Can my customs broker’s address or contact information appear on my Form 5106?
No. CBP’s notice explicitly states that physical addresses, email addresses, and phone numbers on Form 5106 must belong directly to the IOR. Broker addresses, freight forwarder addresses, P.O. boxes, and business service center addresses don’t qualify as the IOR’s physical address. Brokers also can’t submit their own email or phone number in place of the IOR’s.
What is Executive Order 14411 and what does it require?
EO 14411, “Strengthening Customs Enforcement,” was signed by President Trump on June 3, 2026. It directs CBP to tighten importer eligibility requirements, including requiring IORs to disclose beneficial ownership and maintain good standing with CBP. It also calls for risk-based tiering of IORs, enhanced vetting of customs brokers and freight forwarders, and minimum penalty floors, including at least 50% of the assessed penalty, with no mitigation for repeat offenders.