CBP to Enforce Accuracy of Importer of Record Information
Published Aug. 22, 2025
Key Points
- CBP will begin enhanced enforcement of Importer of Record (IOR) information on September 18, 2026. The agency may immediately void an IOR number if information on CBP Form 5106 is inaccurate or incomplete.
- The physical address provided for the IOR must be the actual physical location of the business or individual.
- The email address and phone number must belong directly to the IOR.
- Customs brokers must have a valid Power of Attorney executed directly with the IOR.
- CBP may take additional enforcement action when inaccurate or misleading information appears on CBP Form 5106.
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U.S. Customs and Border Protection (CBP) is implementing enhanced enforcement procedures to verify the accuracy of information provided by new and existing Importers of Record (IORs) on CBP Form 5106. Beginning September 18, 2026, CBP will void an IOR number if it determines that the information provided is inaccurate or incomplete. IORs and customs brokers submitting information on their behalf must ensure the information remains accurate and up to date. CBP will also review existing IOR records, so importers should verify their information before enforcement begins.
IOR Numbers May Be Voided Starting September 18
Beginning September 18, 2026, CBP will void an IOR number if it determines that the IOR or a customs broker acting on its behalf failed to provide complete and accurate information on Form 5106.
A voided IOR number becomes invalid for any purpose, including entering imported merchandise into the United States.
CBP may also take other enforcement actions as appropriate. The agency will send written notice to the IOR’s most recently submitted email address. The notice will explain the basis for the action and provide information about requesting reestablishment of the IOR number.
Requesting Reestablishment of a Voided IOR Number
If CBP voids an IOR number, the notice will explain how the IOR can request reestablishment. CBP may require information that corroborates the identity of the requesting IOR.
An IOR or a customs broker with a valid POA can contact IORProgram@cbp.dhs.gov regarding a voided IOR number. CBP asks that the subject line “Enforcing IOR Accuracy” be used for questions concerning this enforcement effort and requests for reestablishment.
CBP Form 5106 Information Requirements
CBP Form 5106, Create/Update Importer Identity Form, contains information used to identify an IOR.
Required information includes:
- Importer name
- IRS Employer Identification Number (EIN), Social Security Number (SSN), or CBP-assigned number
- Mailing address
- Physical location address, if different from the mailing address
- Phone number
- Email address
The form also includes optional information about the company, business structure, beneficial ownership, and company officers.
CBP is reviewing the Form 5106 information it has on file for IORs.
Address, Email, and Phone Requirements
The physical address provided on Form 5106 must be the actual physical location of the business or individual. The address cannot be:
- A registered agent’s address
- A customs broker’s address
- A freight forwarder’s address
- A P.O. box
- A business service center
- An address belonging to another person or entity
The physical address associated with the business may be the principal’s home address.
The email address and phone number provided on Form 5106 must be valid and belong to the IOR. Customs brokers and other third parties cannot provide their own email address or phone number, or the contact information of another person or entity, instead of the IOR’s information.
What Are the Requirements for Customs Brokers?
Customs brokers submitting Form 5106 information for an IOR must exercise due diligence to verify the information before transmitting it to CBP.
A customs broker must also have a valid Power of Attorney authorizing it to submit information to CBP on behalf of the IOR. The POA must be executed directly between the customs broker and the IOR, rather than through a freight forwarder or another third party.
What Are the Legal Consequences for Inaccurate Information?
The party certifying Form 5106 must take appropriate steps to verify the information before submitting it.
According to CBP, intentional false statements, deception, or fraud on Form 5106 may result in fines, imprisonment, or other legal consequences under applicable federal law.
Because IOR information helps identify the party responsible for duties owed to CBP, inaccurate or misleading information also may create liability under the False Claims Act or other laws.
Customs brokers that submit inaccurate or invalid Form 5106 information may also face broker penalties or other consequences under applicable law.
What Importers and Brokers Should Review
Before September 18, importers and their customs brokers should review the information on file with CBP and correct information that is inaccurate or outdated.
The review should include:
- Importer name
- EIN, SSN, or CBP-assigned number
- Physical address
- Email address
- Phone number
- Other information submitted on Form 5106
- Validity of the broker’s POA
Updates and corrections should be made promptly.
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