CBP Starts Voiding Importer of Record Numbers on September 18 — Check Your 5106 Now

Most importers have never thought twice about their CBP Form 5106. It gets filed once, usually by a broker, usually years ago, and then it sits in the system while entries flow. That era ended this week.

On August 19, 2026, U.S. Customs and Border Protection published a general notice in the Federal Register — “Accuracy of Importer of Record Data Submitted to CBP” (91 FR 53627) — announcing that beginning September 18, 2026, CBP will immediately void the importer of record (IOR) number of any importer whose Form 5106 information is inaccurate or incomplete. A voided IOR number is invalid for every purpose, including making entry. No entry number, no release, no cargo.

What CBP Actually Announced

The notice is the first concrete implementation step under Executive Order 14411, “Strengthening Customs Enforcement,” signed June 3, 2026. Section 2(e) of that order directs DHS to confirm that active importers of record actually comply with applicable regulations and disclosure requirements. CBP's answer is a comprehensive, systematic review of the Form 5106 data it already holds on file.

Three details matter more than the rest:

• It applies to existing importers, not just new ones. CBP says it is reviewing records already on file. A twenty-year history of clean entries does not exempt you.
• There is no cure period described in the notice. CBP does not commit to issuing a request for information, granting time to correct, or holding a hearing before voiding. The void comes first; reestablishment comes after.
• Your broker is on the hook too. If a customs broker transmitted the incomplete or inaccurate information on the importer's behalf, CBP says it may take enforcement action against the broker as well, and will copy the broker that last filed entry on the void notice.

Which Data Fields Are In Scope

Form 5106 carries six required identity fields, and all six are being verified:

1. Importer name
2. IRS Employer Identification Number, Social Security Number, or CBP-assigned number
3. Mailing address
4. Physical location address, where it differs from the mailing address
5. Phone number
6. Email address

The critical word is “belong.” Each of these has to belong to the importer directly. Per the form instructions CBP cites, the physical address must be the address actually associated with the business or the individual — for a small company, the principal's home address is acceptable, but a placeholder is not.

Long-Accepted Practices That Are Now Defects

This is where a lot of otherwise careful importers are exposed. Common setups that CBP now treats as defective include:

• Using the customs broker's or freight forwarder's address as the importer's address of record
• Using a registered agent or incorporation-service address
• A P.O. box or a mailbox/business service center address in the physical address field
• A phone number or email that routes to the broker, a former employee, or a mailbox nobody reads
• Any third party's contact details standing in for the importer's own

A stale email address matters twice over: CBP says it will send the written void notice to the most recently submitted email address on file. An importer with a bad email on record can be voided and not find out until a container sits at the port.

What This Means for Small and Mid-Size Importers

The risk is operational, not theoretical. A voided IOR number stops entry filing cold: cargo held at the terminal, demurrage and per-diem accruing daily, and, if the delay runs long enough, general order. For a small importer running lean inventory, a two-week stoppage on one shipment can cost more than a year of compliance work.

There is a legal dimension too. CBP frames Form 5106 accuracy as information material to an obligation to pay money to the government — language that points toward exposure beyond a voided number, including false statement statutes for intentional misrepresentation and broker penalties under 19 U.S.C. § 1641. A defective certification also hands CBP or DOJ an easy argument that an importer failed to exercise reasonable care in any future penalty case.

Earlier this year CBP deactivated roughly 4.8 million IOR accounts that had not filed an entry within the prior year. This review is the next pass through the registry — systematic, not case by case.

Practical Next Steps Before September 18

1. Pull your own record. Log into the ACE Secure Data Portal and check the 5106 data CBP actually has on your IOR number, field by field, against current corporate records.
2. Fix the address fields first. Confirm the physical address is a real location where your business operates. If your broker's or forwarder's address is sitting in that field, replace it now.
3. Confirm the phone and email reach you. Send a test to the email on file. Make sure a live person monitors it — that is where a void notice will land.
4. Verify your EIN exactly as issued by the IRS. Name/EIN mismatches from a rebrand, merger, or entity conversion are a classic defect.
5. Have your broker re-transmit corrections through ABI, and make sure the supporting power of attorney is current and properly signed.
6. Review every IOR number you use — affiliates, subsidiaries, related entities. Voiding is per-number. Then document what you fixed and when.

If a number does get voided, questions and requests for reestablishment go to [email protected] with the subject line “Enforcing IOR Accuracy.” CBP has not published a turnaround time for reestablishment, which is precisely why this is worth handling before the deadline rather than after.