Free, no power of attorney needed
The 5106 exposure audit
Send us your importer list. We check every record against CBP's August 19, 2026 notice and send back an exposure report per importer. Free, and no power of attorney needed.
Borderless CHB is a licensed U.S. customs broker (CBP filer code NQR) · Checked against Federal Register 2026-16911 on
The rule
Your importers get voided. You find out when the container stops.
On August 19, 2026 CBP publishedAccuracy of Importer of Record Data Submitted to CBP(Federal Register document 2026-16911), issued under Executive Order 14411. The dates paragraph is short and it means what it says: enhanced enforcement, "including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026."
Read that as a forwarder. The voiding itself lands on the importer's number, not on your license or bond. The same notice does warn that whoever certifies the form can face liability under 18 U.S.C. 1001 or the False Claims Act, and that a broker who transmits inaccurate 5106 data can face penalties under 19 U.S.C. 1641. What changed on September 18 is that an importer whose record fails the review can no longer make entry, and the notice CBP sends goes to the email address on that importer's Form 5106. If the address on file is your operations inbox, or an inbox nobody has watched since the record was created, the first signal that reaches anyone is a shipment that will not clear.
There is no cure period. CBP does not write first and void later. It voids, then writes to the importer's most recently submitted email address and, where there is one, copies the customs broker that last filed entry, with the basis for the voiding and how to request that the number be reestablished. CBP has published no timeline for that reestablishment.
The awkward part for a forwarder is that the three defects the notice names outright are the ones forwarder-managed records carry most often: your email address in the importer's email field, your address in the importer's physical address field, and your dispatch line in the importer's phone field. All three were ordinary convenience for years. Since September 18 they are voiding risks sitting on file, up to three per importer.
The record
Seven rows, and what fails in each one
The notice lists six fields CBP verifies on the Form 5106. The seventh row is the power of attorney, which sits in the same notice and needs the same look.
| Field | What CBP requires | What fails, and whose data is usually in there |
|---|---|---|
| Importer name | The importer's legal name, as its tax records carry it. | An old DBA, a trade name, or a name that drifted after a reorganization. Punctuation and suffixes count. |
| IRS number (EIN, SSN, or CBP-assigned number) | The number the IOR number is built on. CBP carries it with a two-character suffix, which is 00 unless the importer uses branch or vessel suffixes (19 CFR 24.5(d)), so what CBP holds is not always the bare EIN. | A parent company's EIN standing in for the entity named on the invoice, or the wrong branch suffix on a multi-division EIN. |
| Mailing address | A current, deliverable address for the importer. | Your office, because mail routing was set up that way years ago and nobody revisited it. |
| Physical location address (if different from the mailing address) | CBP: it “must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.” | Your warehouse or your suite number. The notice names this one outright. |
| Phone number | CBP: it “must be valid and belong to the IOR... Customs brokers or third parties may not supply their own phone number, or the phone number of another person or entity, in place of the IOR's phone number.” | Your dispatch line, or the mobile number of an employee who left. |
| Email address | CBP: it “must be valid and belong to the IOR. Customs brokers or third parties may not supply their own email address, or the email address of another person or entity, in place of the IOR's email address.” | Your operations inbox, or a broker's. This field decides whether anyone reads the voiding notice, because that is where CBP sends it. |
| Power of attorney (same notice, not a field on the form) | CBP: “Customs brokers must execute the POA directly with the IOR, not via a freight forwarder or other third party.” (19 CFR 111.36(c)(3)) | A POA that reached the broker through you. It needs re-executing directly between the importer and the broker. |
Quoted language is verbatim from Federal Register 2026-16911. The notice also reminds brokers of the duty of due diligence under 19 CFR 111.29(a) and 111.32: a broker should not transmit information to CBP it knows or should know is false or misleading, including unverified information.
The offer
Send the list, get a report per importer
Free, with nothing to sign. We built this because the rule lands on forwarders hardest, and most of what is landing in their inboxes about it is wrong.
You send the list
One row per importer: company name, IRS number, mailing address, physical address, phone, and the email on file. A CSV export or a pasted table both work. Nothing to sign.
We read it against the notice
A licensed broker at Borderless (CBP filer code NQR) checks every row against Federal Register 2026-16911 and flags the fields that would not survive it.
You get a report per importer
One page per importer: field by field, what looks clean, what looks like a defect, and the correction each one needs. Free.
You act on it
Most fixes are yours to make with your client. Where a record needs correcting on file, a 5106 update is filed by that importer's broker.
What happens if a record needs correcting
A Form 5106 update is filed by the importer's broker, and it is a routine filing. If that broker is already in place, hand them the report and they can do it. If the importer would rather that became us, the power of attorney is signed directly by the importer at their own email address, verified by a code we send them. The notice requires it: a POA has to be executed directly with the importer of record, never routed through a freight forwarder or another third party, and that is howour forwarder onboarding already works.
Importers you bring stay yours. They get no portal login from us and no marketing from us. We do not sell freight or forwarding, so we are not competing for the account.
How to send it
Two ways, both take a minute
Use the contact form and either attach a CSV or paste the list straight into the message box. One row per importer, with these columns where you have them:
- Company name as it appears on the entry
- IRS number (EIN, SSN, or CBP-assigned number), with the branch suffix if you have it
- Mailing address, and the physical address if it differs
- Phone number and email address currently on file
Partial rows are fine. A blank field is itself a finding, because incomplete information is one of the two triggers in the notice. If you would rather not use the form, email the list to hello@borderlesschb.uswith "5106 audit" in the subject. We treat the list as confidential and use it only for the audit.
Honest limits
What this audit can and cannot tell you
We cannot see CBP's internal record for an importer we do not represent. The audit compares the data you give us to the rule CBP published and tells you which fields would not survive it. That is genuinely useful, and it is not the same as reading the file. Where a record matters, the importer should pull what CBP actually holds, through their own broker or in the ACE Secure Data Portal, and compare it to the report.
Only CBP decides whether a record is accurate and complete, and only CBP decides whether to void a number. Nothing in a report from us prevents a voiding, and a clean report is not a clearance. This page is general information about a published rule, not legal advice about a particular importer.
Questions
What forwarders ask first
What happens if CBP voids my importer number?
The number becomes invalid for any purpose, including entering merchandise into the United States. In practice the cargo stops and the demurrage clock keeps running. CBP then sends written notice to the email address most recently submitted on the Form 5106 and, where there is one, copies the customs broker that last filed entry, explaining the basis for the voiding and how to request reestablishment of the number. There is no advance warning and no cure period before the voiding, and CBP has published no processing timeline for putting a number back.
Can my forwarder use its own email address on my 5106?
No. The August 19, 2026 notice is explicit: the email address submitted must be valid and belong to the importer of record, and customs brokers or third parties may not supply their own email address, or another entity's, in place of the importer's. A separate bullet in the same notice rules out a customs broker's or freight forwarder's address as the importer's physical address, along with a registered agent, a P.O. box, and a business service center.
How do I fix an inaccurate Form 5106?
Pull what CBP actually holds rather than auditing from memory. Your broker can query the importer record, or the importer can view it in the ACE Secure Data Portal. Compare each field to reality, starting with the email address, because that is where the voiding notice goes. Then have a licensed broker holding a valid power of attorney file the corrected Form 5106 electronically. A 5106 update is a routine filing, and it is far cheaper now than after a container has stopped.
Does the audit obligate me to switch brokers?
No. The audit is free and needs no power of attorney. The report is yours to hand to whichever broker files for that importer today. We wrote it to be useful under a rule that lands on forwarders hardest. If you do decide to move filings to us, the importer signs the power of attorney directly with us at their own verified email, which is what the notice requires anyway.
Sources
- Accuracy of Importer of Record Data Submitted to CBP, Federal Register document 2026-16911, published August 19, 2026. The effective date, the six verified fields, the email and physical address restrictions, the power of attorney requirement, and the reestablishment path all come from this notice.
- Executive Order 14411, Strengthening Customs Enforcement, published June 10, 2026. The order the August notice implements.
- 19 CFR part 111, the customs broker regulations, including the due diligence duties at 111.29(a) and 111.32 that the notice cites, and the direct-POA requirement at 111.36(c)(3), which the notice footnotes twice.
- Our longer explainer:CBP Form 5106 enforcement, what to check before September 18.
Written by Borderless CHB. A licensed broker (Joy Xue, CBP filer code NQR) reads every audit. Page checked against the primary sources on .
Send the list, get a report per importer
Send the list and fix what it finds before a shipment stops. The audit is free and needs no power of attorney.