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CBP Warns CTPAT Importers: IOR Numbers May Be Voided Starting Nov. 18

Published Nov. 4, 2026

Key Points

  • CBP may void affected Importer of Record (IOR) numbers starting November 18, 2026, due to concerns about inaccurate or incomplete CBP Form 5106 information.
  • The affected IOR numbers may become invalid for new entries filed beginning at 12:01 a.m. ET on November 18, unless importers satisfactorily address CBP’s concerns.
  • Affected importers must review and correct their Form 5106 information in the ACE Secure Data Portal.
  • Importers must also verify that their IOR numbers remain active in the CTPAT Portal and match their ACE records.
  • Need help? GHY can help file a Form 5106 if needed ahead of Nov. 18.

I​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​n aCanada Border Services Agency officer at a commercial border crossing recent alert shared by the National Customs Brokers & Forwarders Association of America (NCBFAA) Customs Committee, the association said numerous CTPAT-certified importers have received letters from U.S. Customs and Border Protection (CBP). The letters advise that their Importer of Record (IOR) numbers may be voided, effective Nov. 18, due to concerns about the accuracy of information previously submitted on CBP Form 5106. Unless those concerns are satisfactorily addressed, CBP intends to void the affected IOR numbers for entries filed starting at 12:01 a.m. ET on Nov. 18. Importers are urged to review and update their IOR information promptly to avoid any shipment delays.

For background on the policy behind these letters, read GHY’s earlier post: CBP to Enforce Accuracy of Importer of Record Information.

What the CBP Letters Say

NCBFAA said that many CTPAT-certified importers have received letters from CBP about their IOR numbers. The letters say:

  • Affected IOR numbers may be voided, effective Nov. 18.
  • CBP has concerns about the accuracy of information previously submitted on Form 5106.
  • CBP will void the numbers for entries filed starting at 12:01 a.m. ET on Nov. 18, unless those concerns are addressed.

Importers are urged to review their Form 5106 information in the ACE Secure Data Portal, make any necessary corrections, and make sure their IOR numbers in the CTPAT Portal are active and consistent with ACE records.

A voided IOR number can’t be used to enter merchandise, so an unresolved issue could stop your shipments from clearing.

What Importers Should Verify on Form 5106

These requirements come from CBP’s Federal Register notice on IOR data accuracy. Go through each field in ACE. Every one of them needs to belong directly to the importer.

  • Importer Name: Make sure the importer name on file is correct and current.
  • Identification Number: Confirm that the IRS Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned number on file is accurate and belongs to the IOR.
  • Mailing Address: Check that your mailing address is current. If your physical location is different, that address needs to be on file too.
  • Physical Address. This has to be the actual physical location of the business or individual. If you run your business from home, your home address can be used, because the address associated with the business can be the principal’s home address. Remember, physical address can’t be:
    • A registered agent
    • A customs broker or freight forwarder
    • A P.O. box
    • A business service center
    • An address belonging to another person or entity
  • Email Address: The email must be valid and belong to the IOR. Brokers and other third parties can’t use their own email, or anyone else’s, in place of the importer’s. This one matters most: CBP sends voiding notices to the email address most recently submitted.
  • Phone Number: The phone number must also be valid and belong to the IOR. Don’t list numbers that aren’t tied to the importer, and brokers or third parties shouldn’t substitute their own.
  • Other Company Information: Form 5106 also has optional fields for business structure, beneficial ownership, and company officers. If you’ve filled them in, keep them accurate too.
  • Broker Power of Attorney: A customs broker submitting information for you must have a valid POA signed directly with you, not through a freight forwarder or any other third party.

What Importers Should Do Now

  1. Review Form 5106 in ACE. Log in to the ACE Secure Data Portal and correct anything inaccurate, incomplete, or out of date.
  2. Check your CTPAT Portal records. Make sure your IOR numbers are active and consistent with ACE.
  3. Remove third-party details. Replace any broker, forwarder, or service-provider contact information with your own.
  4. Talk to your customs broker. The NCBFAA Customs Committee encourages customs brokers to notify their importer clients, especially those participating in CTPAT, as soon as possible. Your broker can help you review your records and plan corrections before the deadline.

For reference, importers can access the official CBP Form 5106 and NCBFAA Customs Committee’s guidance on verifying importer information in the ACE Portal (for logged-in NCBFAA members).

What Happens If Your IOR Number is Voided

CBP will send a written notice explaining why to the email address you most recently submitted. If a broker last filed an entry for you, CBP will copy them when it can. The notice explains how to request reinstatement, including what information you’ll need to submit to confirm your identity. You or your broker (with a valid POA) can also email IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.”

Need Help With Your Form 5106?

GHY’s customs brokerage and trade compliance team can help you verify your IOR information, spot inconsistencies, and file a Form 5106 if needed ahead of Nov. 18. Contact your GHY representative today to get started.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.

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