CBP Form 5106 IOR Verification Rules: What U.S. Importers Need to Know Before September 18, 2026

The U.S. Customs and Border Protection (CBP) is moving toward a more rigorous approach to verifying the identity and information of Importers of Record (IORs).

On August 19, 2026, CBP published a notice in the Federal Register announcing enhanced enforcement procedures for verifying the accuracy of information submitted through CBP Form 5106, the Create/Update Importer Identity Form. The new enforcement measures are scheduled to begin on September 18, 2026.

For U.S. importers, the development is another indication that importer identity, business information and customs compliance are becoming increasingly important elements of the U.S. import process.

From Importer Identification to Enhanced Verification

CBP Form 5106 has long been part of the process for establishing an Importer of Record number. The form collects basic information used by CBP to identify the entity or individual responsible for an import transaction.

The information includes the importer’s name, EIN, SSN or CBP-assigned number, mailing address, physical location address when different, telephone number and email address.

What is changing is not simply the information requested on the form, but the level of attention CBP is placing on the accuracy and authenticity of that information.

Under the August notice, CBP is reviewing information already maintained for existing IORs as well as information submitted for new importers. CBP states that importers and customs brokers acting on their behalf must ensure that the information provided is complete and accurate.

Beginning September 18, if CBP determines that the information associated with an IOR is inaccurate or incomplete, the agency may immediately void the IOR number. Once voided, that number would no longer be valid for entering imported merchandise into the United States.

The notice therefore places greater emphasis on maintaining current importer records rather than treating Form 5106 as a one-time registration document.

The Physical Address Is Receiving Particular Attention

One of the most important points in the new CBP notice concerns the physical location address.

CBP states that the physical address provided for an IOR must represent the actual physical location of the business or individual. It cannot be replaced by the address of a registered agent, customs broker, freight forwarder, P.O. box, business service center, or another unrelated entity.

This requirement is also consistent with the existing instructions for CBP Form 5106. The current form explains that the physical location address must be associated with the business or individual and cannot be a P.O. Box or business service center. It also notes that, where applicable, the principal’s home address may serve as the physical business address.

For companies that have changed offices, relocated operations, reorganized their corporate structure, or used third-party addresses in the past, this distinction may be particularly relevant.

Email and Telephone Information Also Need to Belong to the IOR

The enhanced verification is not limited to physical addresses.

CBP specifically states that the email address and telephone number submitted on Form 5106 must be valid and belong directly to the IOR. A customs broker, freight forwarder or other third party should not substitute its own contact information for that of the importer.

This is significant because contact information is increasingly used as part of identity verification and communication between importers, brokers and government agencies.

CBP’s ACE importer portal, for example, uses the point-of-contact email associated with the importer record when sending a verification code for certain account applications.

Keeping the contact information current can therefore become important not only for compliance purposes, but also for receiving time-sensitive communications from CBP.

The Policy Is Part of a Broader Customs Enforcement Direction

The latest Form 5106 action should also be viewed within the broader customs enforcement policy introduced earlier this year.

On June 3, 2026, the White House issued Executive Order 14411, “Strengthening Customs Enforcement.” The order directed the Department of Homeland Security and CBP to take steps toward stronger importer eligibility requirements, enhanced importer information, additional disclosures, improved verification procedures and continuing review of IOR compliance.

The order also calls for CBP to update the IOR registry, remove inactive importers, confirm that active IORs comply with applicable regulations and disclosures, and establish risk-based tiers based on factors such as compliance history and enforcement actions.

In other words, the August Form 5106 notice represents one concrete step within a broader effort to strengthen the U.S. customs system.

The White House has described the policy in terms of protecting customs revenue, improving accountability and preventing unlawful imports. The executive order specifically identifies accurate identification of IORs as an important part of ensuring that the appropriate party remains accountable for duties and other customs obligations.

Why IOR Accuracy Matters to Importers

An Importer of Record is not simply a name attached to a customs entry.

The IOR is closely connected to responsibilities for customs declarations, duties, taxes, fees and compliance with applicable U.S. laws. Congressional research has similarly described the importer of record as having a general obligation to exercise reasonable care and provide the information necessary for CBP to assess duties and determine compliance with U.S. requirements.

Recent reporting also reflects a broader shift in the U.S. customs environment.

Reuters reported in August 2026 that U.S. authorities have been increasing the use of civil and criminal enforcement tools in customs-related cases, with investigations extending beyond traditional duty issues to areas such as origin, forced labor, product safety and other forms of trade fraud.

Meanwhile, reporting by The New York Times has highlighted how the rapid expansion of U.S. tariff collections has increased the financial importance of import transactions and placed significant responsibility on importers of record, many of which are U.S.-based businesses.

Taken together, these developments point to a customs environment in which the identity of the importer and the accuracy of the information associated with that importer are becoming increasingly significant.

What U.S. Importers May Want to Review

The September 18 enforcement date gives importers an opportunity to review their existing records.

Companies that regularly import into the United States may wish to compare their current business information against the information maintained through Form 5106, including:

• Legal importer name
• EIN, SSN or CBP-assigned importer number
• Mailing address
• Physical business address
• Telephone number
• Business email address
• Corporate and business information where applicable
• Customs broker authorization and Power of Attorney arrangements

The most important principle is consistency.

The information maintained by CBP should accurately reflect the actual importer rather than a broker, freight forwarder, registered agent or another third party.

For companies that have changed their registered office, physical location, contact person, corporate structure or other relevant information, reviewing whether the CBP record remains current may help reduce the possibility of problems during future customs transactions.

What Happens if an IOR Number Is Voided?

CBP’s August notice provides a procedure for addressing a voided IOR number.

If CBP determines that an IOR’s information is inaccurate or incomplete, the agency will issue written notification to the most recent email address submitted for the IOR. The notice will explain the basis for the action and, where applicable, provide information on how the importer can request reestablishment of the IOR number.

This means that an IOR number being voided does not necessarily represent an irreversible situation. However, the importer would need to address the underlying information issue and provide appropriate documentation to support its identity and request for reestablishment.

For importers with regular shipments, resolving such an issue before a shipment is ready to enter the United States may be considerably easier than dealing with an invalid IOR during an active import transaction.

September 18, 2026: An Important Compliance Date

The CBP notice establishes September 18, 2026 as the date when the enhanced enforcement measures, including immediate voiding of IOR numbers associated with inaccurate information, will commence.

The measure does not represent a complete overhaul of the U.S. import process. Rather, it is one part of a broader customs enforcement program aimed at improving importer accountability and the quality of information available to CBP.

For U.S. importers, the practical takeaway is straightforward: accurate company information is becoming an increasingly important part of maintaining a functioning customs profile.

Companies that have not reviewed their Form 5106 information recently may consider using the period before September 18 to confirm that their importer name, identification number, physical address and direct contact information remain accurate and current.

As U.S. customs enforcement continues to evolve, maintaining reliable importer records will remain an important part of preparing for future changes in customs compliance.