CBP Form 5106: What "Accurate and Complete" Means Now
On August 19, 2026, CBP published a Federal Register notice that puts real teeth behind Executive Order 14411's customs enforcement mandate. Starting September 18, 2026, an importer of record (IOR) number can be voided immediately over inaccurate or incomplete information on CBP Form 5106. This isn't limited to new importers: CBP has said it's reviewing the data behind every IOR number on file, whether the account was opened last month or decades ago.
What changed
Executive Order 14411, "Strengthening Customs Enforcement," was signed June 3, 2026. Section 2(e) directs the Department of Homeland Security to confirm that active importers of record are compliant with all applicable regulations and disclosures. CBP's August 19 notice, Federal Register Notice 2026-16911 (91 FR 53627), is the first concrete enforcement step under that directive, and it targets something most importers haven't thought about in years: the identity data on CBP Form 5106, the Create/Update Importer Identity Form every IOR number is built on.
What's on the form
CBP Form 5106 requires six core data elements: importer name; IRS EIN, SSN, or CBP-assigned number; mailing address; physical location address, if different from the mailing address; phone number; and email address. It also includes optional fields for company, business structure, beneficial ownership, and company officers.
What CBP is actually checking
The notice is specific about what "accurate and complete" means. Four things must belong directly to the IOR, not to a broker, forwarder, or other third party acting on its behalf:
Physical address
Has to be where the IOR actually is, not a broker's office, a freight forwarder, a registered agent, a business service center, a P.O. box, or someone else's address.
Email address
Has to belong to the IOR, not whoever's filing on their behalf.
Phone number
Same idea. It has to be a number that actually reaches the IOR, not the broker's line.
Power of Attorney
Has to run directly between the broker and the IOR, with no freight forwarder or other third party standing in the middle.
If CBP determines the information is inaccurate or incomplete, the IOR number is voided immediately. A voided number is invalid for any purpose, including clearing goods into the United States.
What happens if you're flagged
- CBP voids the IOR number and sends written notice to the last email address on file, copying the broker who last filed on the IOR's behalf.
- Getting a voided number reestablished means proving identity and ownership to CBP. Historically, that's taken about five business days.
- In the meantime, the IOR cannot make entry. Shipments already in transit have nowhere to clear.
- The certifying party can face fines or imprisonment under 18 U.S.C. § 1001 for a false statement, and inaccurate data tied to duty liability can raise False Claims Act exposure. Brokers who submit inaccurate information may face broker penalties under 19 U.S.C. § 1641.
- Questions and reestablishment requests go to CBP directly at IORProgram@cbp.dhs.gov, subject line "Enforcing IOR Accuracy."
A separate way your IOR number can stop working
Form 5106 accuracy isn't the only thing that can shut down an IOR number this year. Since July 16, 2026, CBP has been automatically marking IOR accounts "Inactive for Entry Purposes" in ACE if no entry has been filed under that number in the past 366 days, under 19 CFR 24.5(e). An inactive number can't transmit ACE Cargo Release or Entry Summary transactions until it's reactivated, a separate process CBP published back on June 26, 2026. CBP is rolling this out in stages, starting with the longest-dormant accounts, so a number can go inactive quietly, sometimes with no other sign anything changed, until a broker tries to file and it doesn't go through.
A control worth considering: the Freeze Program
CBP has had a voluntary program for years that most importers have never heard of, and it's worth a second look now. Under 19 CFR 24.5(f), you can designate specific named individuals as the only people authorized to change your Importer Record Number's name or address. Once an account is "frozen," CBP's Surety Bonds & Accounts Team will only process a change if it's signed by one of those designated people, not just anyone submitting a Form 5106 on the account's behalf.
Enrolling means sending a separate letter, on company letterhead, signed by the IOR or an authorized agent with their name and title clearly stated, referencing 19 CFR 24.5(f) by name, and stating the mailing or physical address for CBP notifications. It goes to bondquestions@cbp.dhs.gov with the subject line "Frozen IR #XX-XXXXXXXX." Leaving the program later works the same way, in writing, referencing the same regulation, requesting removal.
What to do now
- Log into the ACE Secure Data Portal and check your company's Importer Account Profile for the physical address, email, and phone number CBP currently has on file. If you don't have ACE Portal access yet, CBP's Applying for an ACE Portal Account page walks through it, or call CBP's ACE technical support line at 866-530-4172. Your customs broker can also pull and confirm this for you directly.
- Confirm your broker's Power of Attorney runs directly to you, not through a freight forwarder or other intermediary.
- Consider whether the Freeze Program is worth enrolling in for accounts where you want tighter control over who can change your IOR information.
- If any of this looks off, or you're just not sure, get it checked before September 18.
Not sure where your account stands?
Our Import Partner Readiness Check walks through this, and seven other factors tied to EO 14411, in about five minutes, with a downloadable record at the end.
Take the Readiness Check