Executive summary

On 19 August 2026, US Customs and Border Protection (CBP) published a general notice in the Federal Register titled "Accuracy of Importer of Record Data Submitted to CBP" (notice), notifying the public that it is taking initial steps to implement Executive Order (EO) 14411 titled "Strengthening Customs Enforcement," signed on 3 June 2026. Consistent with Section 2(e) of the EO, which directs the Department of Homeland Security to confirm that active importers of record (IORs) comply with applicable regulations and disclosures, CBP is implementing enhanced enforcement procedures to verify the accuracy of the information used to identify and validate IORs on CBP Form 5106, Create/Update Importer Identity Form.

Effective 18 September 2026, CBP will void the IOR number of any importer, or customs broker acting on the importer's behalf, that has failed to provide complete and accurate information on Form 5106. A voided IOR number is invalid for any purpose, including entering merchandise into the United States. CBP has indicated it may also pursue other enforcement actions as appropriate.

For more on EO 14411, "Strengthening Customs Enforcement", see EY Global Tax Alert, US President issues Executive Order strengthening customs enforcement; enhanced importer requirements, disclosure obligations and penalties announced, dated 4 June 2026.

Accuracy requirements for CBP Form 5106

CBP is comprehensively reviewing Form 5106 information on file for accuracy. IORs, or customs brokers acting on their behalf, must ensure that all information is accurate, complete and belongs directly to the IOR. The notice identifies specific requirements, including:

• Physical address. The physical address must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, PO box, business service center or the address of another person or entity. As explained in the Form 5106 instructions, the address may be the principal's home address where associated with the business or individual.
• Email address. The email address must be valid and belong to the IOR. Customs brokers or third parties may not substitute their own email address or that of another person or entity.
• Phone number. The phone number must be valid and belong to the IOR. Numbers not associated with the IOR should not be submitted.

The party certifying Form 5106 must take appropriate steps to verify the information before submission. Customs brokers submitting the form on behalf of a client must hold a valid power of attorney executed directly with the IOR, not through a freight forwarder or other third party, and must not transmit information they know or should know is false, misleading or unverified.

Enforcement and potential exposure

Because IOR data is a key identifier for duty liability, CBP has stated that inaccurate or misleading information is material to the obligation to pay money to the government. The certifying party may face further legal consequences for intentional false statements, deception or fraud on Form 5106, and inaccurate submissions may subject the IOR or associated individuals to liability under federal false claims and false statement statutes. Customs brokers submitting inaccurate or invalid information may also be subject to broker penalties.

Voiding and reestablishment procedure

If CBP determines that the Form 5106 information is inaccurate or incomplete, it will, as of 18 September 2026, immediately void the associated IOR number. CBP will issue written notice of the action to the email address the IOR most recently submitted, stating the basis for the voiding and explaining how to request reestablishment, including the information needed to corroborate the requesting IOR's identity. Where applicable, CBP will copy the customs broker that last filed entry on the IOR's behalf. The IOR, or a customs broker holding a valid power of attorney, may direct questions regarding a voided IOR number to CBP to IORProgram@cbp.dhs.gov using the subject line "Enforcing IOR Accuracy."

What this means for businesses

The notice moves IOR data accuracy from a routine administrative matter to an enforcement priority with immediate consequences. A voided IOR number would halt an importer's ability to make entry, creating supply chain disruption, potential demurrage and delivery delays until the number is reestablished. Foreign IORs, importers using complex ownership structures and businesses that historically relied on third-party or intermediary contact information face heightened risk. Customs brokers also carry direct exposure, given the due diligence and power of attorney requirements and the potential for broker penalties.

Actions to consider

Actions for businesses to consider, depending on their specific situations, include the following:

• Review current CBP Form 5106 records to confirm the physical address, email address, phone number and tax identifiers are accurate, complete and belong directly to the IOR.
• Confirm and correct, if necessary, any Form 5106 information that lists a registered agent, customs broker, freight forwarder, PO box, business service center or third-party address before 18 September 2026.
• Confirm that customs brokers hold a valid power of attorney executed directly with the IOR and have verified the underlying data.
• Establish an internal process to keep IOR identity information current and to certify accuracy before submission.
• Monitor forthcoming CBP rulemaking and guidance on importer eligibility issued under EO 14411.

Implications

The notice signals that IOR data accuracy is an early and enforceable priority under EO 14411, and that CBP is separately revising importer eligibility regulations, guidance and policies. Further announcements are expected through the CBP website and the Federal Register.