Your next shipment could sit at the port, uncleared and racking up storage charges, because of a form someone filled out years ago and never looked at again. Starting today, September 18, 2026, U.S. Customs and Border Protection will immediately void importer of record numbers when the information on CBP Form 5106 is inaccurate or incomplete. A voided number is invalid for every purpose, including making entry — which means your cargo stops moving with no advance warning and no grace period to fix the paperwork.
This is not a proposal or a pilot program. CBP announced the enforcement date in a Federal Register notice published August 19, 2026, and the agency says it is comprehensively reviewing the Form 5106 data on file for every importer of record. If you import anything into the United States — whether you bring in full containers or a few parcels a month through a customs broker — here is what is changing, which records are most exposed, and what to do right now.
What Changed on September 18, 2026
CBP's Federal Register notice states the new rule plainly: beginning September 18, 2026, if CBP determines that an importer of record, or a customs broker acting on the importer's behalf, failed to provide complete and accurate information, CBP will void the IOR number and may take other enforcement action as appropriate.
Three things make this enforcement push different from routine record-keeping reminders:
Voiding is immediate and total. A voided IOR number cannot be used for any purpose, including entering imported merchandise. Your broker cannot file an entry under it. There is no provisional status and no temporary workaround while you sort out the paperwork.
There is no cure period. The notice describes no request for information, no warning letter, and no hearing before voiding. The voiding action comes first; reestablishment comes after, on a timeline CBP has not published.
The review is systematic, not case by case. Earlier this year, CBP deactivated roughly 4.8 million importer accounts that had not filed an entry within the preceding year, and in July it introduced a new "Inactive for Entry Purposes" status in the Automated Commercial Environment (ACE). The agency is working through the importer registry methodically. This action implements Executive Order 14411, "Strengthening Customs Enforcement," signed June 3, 2026, which directs Homeland Security to confirm that active importers are compliant with all applicable regulations and disclosures.
The Three Fields CBP Is Checking
The notice singles out three data elements in particular that must be complete, accurate, and belong directly to the importer of record. The notice also covers identification numbers — your EIN or Social Security number must be accurate — but the address and contact fields are where most small importers will find problems.
1. Physical address: your actual location, no substitutes
The physical address on file must be the actual physical location of the business or individual. CBP expressly excludes:
- A registered agent's address
- A customs broker's address
- A freight forwarder's address
- A P.O. box
- A business service center or mail drop
- The address of any other person or entity
One accommodation exists: the Form 5106 instructions do permit a principal's home address to serve as the address associated with the business. So a home-based importer can list a home address — but not the accountant's office, the lawyer's office, or the warehouse run by someone else.
2. Email address: valid, and yours
The email address must be valid and belong to the importer of record. A broker or third party may not substitute its own email address or the address of another entity. This field matters twice over, because it is also the channel CBP uses to notify you that your number has been voided — more on that trap below.
3. Phone number: valid, and yours
Same rule. The phone number must be valid and belong to the importer. Numbers not associated with the IOR should not be submitted.
The Long-Accepted Habits That Are Now Defects
For years, brokers and forwarders filled in their own contact details on client records as a convenience, and nobody objected. That era ended today. Consider who this actually captures:
- Non-resident importers that listed a U.S. broker's address because they have no U.S. premises.
- Delivered duty paid (DDP) arrangements where the foreign seller is the importer of record and the forwarder's contact details populate the record.
- E-commerce sellers using a third-party fulfillment center address as their physical location.
- Small importers whose accountant, registered agent, or broker completed the form years ago and never revisited it.
Every one of these records is now exposed. For customs brokers, the exposure multiplies across the client base: a brokerage that populated its own address, email, or phone across hundreds of client records now has hundreds of potential defects, each of which CBP treats as unverified information transmitted to the agency.
Brokers face a related requirement on powers of attorney. Under 19 CFR 111.36(c)(3), the broker must hold a power of attorney executed directly with the importer of record. A POA obtained through a freight forwarder or other intermediary does not satisfy the regulation, and brokers should re-execute those now rather than after CBP asks.
The Notification Trap: You May Not Find Out Until Cargo Stops
Here is the circular problem at the heart of this enforcement action. CBP will issue written notice of the voiding to the email address the importer most recently submitted to CBP, copying the customs broker that last filed an entry on the importer's behalf if applicable.
Read that alongside the email requirement and the trap is obvious: the importers most likely to have a defective email address on file are precisely the importers least likely to receive the notice telling them their number was voided. Many will learn about it only when a broker cannot file an entry — with freight already at the port, demurrage and storage charges accruing daily, and general order exposure looming if the goods sit uncleared.
Assigning an owned, monitored email address is therefore the single highest-value fix in this entire exercise. Use a domain the importer controls and a mailbox a compliance-responsible employee actually reads — not a personal inbox that goes dark when someone leaves the company.
The Liability Does Not Stop at a Voided Number
CBP frames inaccurate Form 5106 data as material to an obligation to pay money to the government. That framing is deliberate, and it opens doors beyond a voided number:
- The certifying party may face fines or imprisonment under 18 U.S.C. § 1001 for an intentional false statement.
- Inaccurate or misleading Form 5106 information could create liability under the False Claims Act, 31 U.S.C. § 3729 and following, which carries treble damages and qui tam exposure.
- Customs brokers face due diligence obligations under 19 CFR 111.29(a), the prohibition on transmitting false or misleading information under 19 CFR 111.32, and monetary penalties under 19 U.S.C. § 1641.
Accurate Form 5106 data also removes a straightforward point of attack in any future penalty case, where CBP or the Department of Justice could otherwise point to a defective certification as evidence bearing on reasonable care and culpability.
What to Do Right Now: An 8-Step Checklist
The enforcement date is here, so treat this as urgent rather than routine. Work through this sequence immediately:
1. Pull the actual data on file
Do not rely on what you believe was submitted. Request your current Form 5106 record through your customs broker or the ACE Secure Data Portal, and review the physical address, mailing address, email address, phone number, and identification number exactly as CBP sees them today.
2. Test each field against the disqualifiers
For the physical address, ask whether an officer visiting that location would find your business operating there. If the answer involves a mail service, a registered agent, a lawyer, an accountant, a broker, a forwarder, or a warehouse operated by someone else, the field needs to change.
3. Assign an owned, monitored email address
As explained above, this is the highest-value fix because it is also the channel through which CBP will tell you something has gone wrong. Fix it first.
4. Audit powers of attorney
Brokers should confirm that every active POA was executed directly with the importer and that the signer had authority to bind the entity. Importers should ask their broker to confirm the same.
5. Re-examine non-resident and DDP structures
A foreign entity acting as importer of record without a U.S. physical location faces a structural problem, not a data-entry problem. That analysis should be run against the broader eligibility framework Executive Order 14411 sets in motion, including bonding, tangible domestic asset, and good standing requirements still to be defined in rulemaking.
6. Correct through the proper channel and document everything
Updates are filed via ABI (through your broker) or by email to the assigned Center of Excellence and Expertise. If no Center has been assigned, use the Center aligned to the HTSUS classification of your highest-valued commodity. Retain the submission, the date, and CBP's confirmation — that paper trail is your evidence of reasonable care.
7. Evaluate whether a correction is also an admission
If a prior certification was knowingly inaccurate, the correction itself may create exposure under 18 U.S.C. § 1001 or the False Claims Act. Speak with customs counsel before filing so the correction is sequenced with any prior disclosure analysis rather than made in isolation.
8. Calendar recurring verification
Treat Form 5106 accuracy as a standing compliance control with an owner and a review date, not a one-time registration task. Address changes, entity restructurings, and personnel departures all break the record silently.
If Your Number Is Already Voided: How Reinstatement Works
If your broker tells you an entry cannot be filed, or you receive a voiding notice, move fast — every day of delay adds port storage costs. The notice itself includes information on how to request reestablishment, and questions about the enforcement effort go to [email protected] with the subject line "Enforcing IOR Accuracy."
CBP's standing Voided Importer Record FAQs describe the mechanics of getting a voided record reinstated:
- What to send: a completed CBP Form 5106, valid importer record proof, and a power of attorney no more than one year old if the form is signed by an attorney-in-fact. Email the package to [email protected] with the subject line "Void IR#."
- Who must sign: an officer of the company (president, vice president, secretary, treasurer, CEO, COO, or equivalent) or a broker holding a power of attorney.
- Proof of EIN: pre-printed documentation received from the IRS within the last 12 months showing the correct EIN and company name — for example Form 147C, a recent Form 941, Form 1120 or 1120-S, or Form 1065. W-9s, SS-4 applications, and state documents are not acceptable. If you need an EIN verification letter, call 1-800-829-0115 to request a 147C letter.
- How long it takes: allow five business days for processing.
- No news is good news: CBP does not contact you when the account is reactivated. If you hear nothing within two business days of submitting, query CBP systems to confirm the account is active; a representative will only reach out if there is a problem with your documents. You are responsible for telling your broker and forwarder to resume activity.
- Helpdesk: the Surety Bonds and Accounts helpdesk at (317) 614-4880 responds within two business days if you reach voicemail.
One important distinction: if your record is merely inactive rather than voided, any licensed broker with ABI access can reactivate it by retransmitting the data to CBP — no email package required.
Track the Compliance Costs Like Any Other Business Expense
Voiding enforcement turns a paperwork chore into a financial event, and your books should reflect that. Demurrage, port storage, general order fees, broker re-filing charges, and customs counsel bills all flow from a single root cause, and lumping them into general expenses hides the true cost of the disruption — and weakens any later claim or penalty-mitigation argument that depends on showing what you spent to fix things.
Create separate expense accounts for trade compliance costs and port disruption charges, and keep the supporting documents — your corrected Form 5106 submission, CBP's confirmation, and every invoice — filed with the period they belong to. If you reconcile freight and duty accruals monthly, add a standing line item that confirms your importer record details are still current; a five-minute check each month beats a five-day scramble with cargo on the dock. Plain-text accounting makes this kind of audit trail trivial to maintain: every correction, fee, and confirmation lives in version-controlled text you can search years later. The Beancount documentation walks through account structures that handle exactly this kind of event-driven expense tracking.
Keep Your Trade Records Organized Before the Next Enforcement Wave
CBP has signaled clearly that importer-registry enforcement is a campaign, not a one-off notice — more eligibility requirements on bonding, domestic assets, and good standing are still working through rulemaking. The importers who sailed through today are the ones whose records were already accurate, documented, and easy to verify. Beancount.io provides plain-text accounting that gives you complete transparency and control over your financial data — no black boxes, no vendor lock-in. Get started for free and see why developers and finance professionals are switching to plain-text accounting.
