CBP Form 5106 enforcement: what to check before September 18

TL;DR: Starting September 18, 2026, CBP will void importer of record numbers whose identity data on file (CBP Form 5106) is inaccurate or incomplete. This covers existing importers, not just new ones. A voided number stops your cargo at the port. CBP is checking six fields: legal name, tax ID, mailing address, physical address, phone, and email. The contact details must be genuinely yours, not your broker’s or forwarder’s. There is no CBP document checklist. Emails demanding wet signatures, passports, or utility bills are a broker’s own policy, not the rule. The fix is simple and cheap right now: pull your record, compare it to reality, and file an update for anything stale.

If you import into the United States, or you’re a freight forwarder whose clients do, a short CBP notice published on August 19 deserves ten minutes of your week. Alarming versions of it are already landing in inboxes. Some come with long document checklists CBP never published. This is the accurate version, checked against the Federal Register notice itself, with the steps that actually matter.

What is CBP Form 5106, and why your importer number depends on it

CBP Form 5106 is the “Create/Update Importer Identity Form.” It’s how an importer of record (IOR) number comes into existence, and how the identity behind it gets updated. For most U.S. companies the IOR number is simply the IRS EIN. Individuals can use an SSN, and foreign companies without a U.S. tax ID get a CBP-assigned number.

The form carries six core facts: legal name, tax ID, mailing address, physical address, phone number, and email address. Every entry filed in your name rides on that record. Most importers have never seen their own 5106. A broker filed it once, years ago, and nobody has looked at it since. That is exactly the problem CBP is now targeting.

What changes on September 18, 2026

The notice (Federal Register 2026-16911, implementing Executive Order 14411, “Strengthening Customs Enforcement”) announces enhanced verification of importer identity data, for new and existing IOR numbers. The enforcement is blunt:

• If CBP determines the data on file is inaccurate or incomplete, it will immediately void the IOR number. There is no published grace period.
• A voided number is invalid for every purpose, including making entry. Cargo stops at the port, and demurrage and storage clocks keep running while it sits.
• The voiding notice goes to the email address on file, with a copy to the broker who last filed for you. If that email is stale, you may learn about the voiding from a stopped shipment instead.
• Reactivation runs through a CBP inbox (IORProgram@cbp.dhs.gov, subject line “Enforcing IOR Accuracy”) on no published timeline.

Voiding an importer record isn’t new. CBP has long voided records over things like undeliverable mail and bond issues. What’s new is the scope and the posture: a systematic accuracy review of the whole importer base, with immediate voiding as the default consequence.

The six fields CBP is checking, and the three rules with teeth

Your physical address must be your real business location

CBP specifically rules out a customs broker’s address, a freight forwarder’s address, a P.O. box, a registered agent, and business service centers. The address must be where your business actually operates, like an office or a warehouse you run. This was always the intent of the form. Now it is an enforced rule. If your record was set up “care of” your forwarder or broker years ago, that is a voiding risk sitting on file.

Your email and phone must belong to you

A broker or forwarder may not stand its own contact details in for yours. For years this was common convenience practice: the broker’s ops inbox went on the form because the broker handled everything. Under the new rule that is a defect, and a dangerous one, because the email on file is where the voiding notice goes. Use a monitored mailbox on a domain you control, not a personal address that leaves with an employee.

Your legal name must match your tax records exactly

“ABC Trading LLC” and “ABC Trading, L.L.C.” are different strings to CBP’s matching. Check your name character by character against your IRS record. That means the CP-575 letter you received when your EIN was issued, or a 147C letter you can request from the IRS. Punctuation, spacing, and suffixes all count.

The remaining fields, mailing address and tax ID, follow the same principle: current, complete, and genuinely yours.

What the notice does not require

CBP published no document checklist with this enforcement. You may have received an email demanding a wet-signature power of attorney, the owner’s passport for a U.S. company, lease agreements, utility bills, or phone-bill verification. That is an individual brokerage’s own vetting policy. Some of it is reasonable diligence. None of it is what CBP published. Electronically signed POAs remain valid, exactly as before.

What the notice does say about brokers is stricter and simpler. A broker must hold a power of attorney executed directly with the importer, not routed through a freight forwarder or any third party. And a broker may not transmit information it knows or should know is false or unverified. Verifying who you are is your broker’s legal duty. Demanding documents CBP never asked for is their choice. It’s fair to know the difference, and it’s fair to ask your broker which is which. That duty of reasonable care runs both ways: importers owe accurate data, and brokers owe diligence in what they file.

How to check and update your Form 5106 in five steps

1. Pull what CBP actually has on file. Ask your customs broker to query your importer record, or view it yourself in the ACE Secure Data Portal if your company has an account. Don’t audit from memory. Records set up years ago routinely carry an old suite number or a departed employee’s email.
2. Fix the email first. It’s where the voiding notice would go. Make it a monitored mailbox on a domain your company controls.
3. Test the physical address against the disqualifier list. If what’s on file is your forwarder, your broker, a registered agent, a P.O. box, or a virtual office, replace it with your real place of business.
4. Match the legal name to your IRS letter, character by character. CP-575 or 147C is the reference document.
5. File the update. A licensed broker submits the corrected 5106 electronically through ABI. It can also go by email to your assigned CBP Center of Excellence and Expertise. Updates are routine filings. They’re cheap insurance now, versus a stopped shipment on CBP’s clock later.

One more item isn’t on the form but is part of the same enforcement. If your power of attorney was ever routed through a freight forwarder rather than signed directly with your broker, re-execute it directly. That requirement is now explicit.

If your importer number gets voided anyway

Don’t file new entries against the voided number. They won’t be accepted. The reestablishment request goes to CBP’s importer program inbox with the corrected information and support that corroborates your identity. Loop your broker in immediately: they received a copy of the voiding notice and can prepare the corrected 5106 while you gather documents. And plan for the delay. CBP has published no processing timeline, so anything on the water needs a contingency conversation with your broker about timing.

If you’re a freight forwarder

Your clients’ importer records are your service continuity. Three things belong on your list before September 18:

• Sweep your book. Any client whose 5106 lists your address, email, or phone is carrying a voiding risk. It will land on your operations desk as a stopped container.
• Re-execute relayed POAs. If any client’s POA historically passed through you on its way to a broker, it needs to be re-signed directly between the importer and the broker. This is how our forwarder onboarding works by default: you generate the link, and your importer signs directly with us.
• Watch the foreign-IOR corner. A foreign importer with no real business address fails the physical-address rule structurally. The foreign importer of record rules are tightening on every front this year. For many of these shipments a U.S. importer of record is now the cleaner structure.

Frequently asked questions

What is CBP Form 5106? The form that creates and updates your importer of record number. It holds your legal name, tax ID, addresses, phone, and email on file with CBP. Every importer has one, even if a broker filed it long ago.

Can CBP really void an existing importer number? Yes. From September 18, 2026, inaccurate or incomplete 5106 data means immediate voiding, for existing importers as well as new ones. A voided number cannot make entry.

How do I check what CBP has on file? Through your broker, or in the ACE Secure Data Portal if you have an account. Compare every field to reality, starting with the email address.

Do I need a wet-signature POA, my passport, or utility bills? No. CBP published no document checklist. Those demands are individual brokers’ policies. E-signed POAs remain valid.

How long does reactivation take? CBP hasn’t said. That is the strongest argument for a ten-minute check now instead of an open-ended delay later.

Does this apply to foreign importers? Yes, and hardest of all. No real business location means a structural problem the form can’t fix. Case-by-case restructuring with a U.S. IOR is often the answer.

The ten-minute version

Pull your record. Fix the email. Verify the physical address is really yours. Match the name to the IRS letter. File the update. If you’re switching brokers anyway, fold the 5106 review into the switch. A good broker verifies your identity data rather than copying it over.

At Borderless, this notice didn’t change our onboarding. It describes it. Every importer signs their POA directly with us at their own verified email, and the details that go on file are the importer’s own. If you’d like a second set of eyes on what CBP currently holds for your importer number, that’s a quick, no-obligation conversation.

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Reviewed August 25, 2026, against Federal Register 2026-16911. This is general information, not legal advice. The rules are moving quickly in 2026, so verify current status or ask us about your specific situation.